4>EPA
United States
Environmental Protection
Agency
FINAL
FY2014
OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION
NATIONAL PROGRAM MANAGER
GUIDANCE
PUBLICATION NUMBER: 743R13001
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FINAL FY 2014 OCSPP NPM GUIDANCE
TABLE OF CONTENTS
I. AGENCY OVERVIEW TO THE FY 2014 NPM GUIDANCES 4
II. INTRODUCTION 4
III. OCSPP'S NATIONAL AREAS OF FOCUS FOR FY 2014 4
IV. NATIONAL AREAS OF FOCUS FOR THE OFFICE OF PESTICIDE PROGRAMS 6
1. NATIONAL AREA OF FOCUS: SCHOOL INTEGRATED PEST MANAGEMENT (TPM) 6
2. NATIONAL AREA OF FOCUS: STRENGTHENING STATE/TRIBAL PARTNERSHIPS THROUGH
CONTINUED EFFECTIVE MANAGEMENT OF GRANTS/ COOPERATIVE AGREEMENTS 7
3. NATIONAL AREA OF FOCUS: COORDINATING WITH STATE/TRIBAL PESTICIDE AGENCIES AND
REGIONAL WATER PROGRAMS TO OBTAIN PESTICIDE WATER QUALITY MONITORING DATA
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4. NATIONAL AREA OF FOCUS: REGION-SPECIFIC PESTICIDE PRIORITIES 10
V. NATIONAL AREAS OF FOCUS FOR THE OFFICE OF POLLUTION PREVENTION
AND TOXICS 12
1. NATIONAL AREA OF FOCUS: LEAD RISK REDUCTION PROGRAM 12
2. NATIONAL AREA OF FOCUS: CHEMICAL RISK MANAGEMENT PROGRAM 16
3. NATIONAL AREA OF FOCUS: POLLUTION PREVENTION PROGRAM 19
VI. PROGRAM-SPECIFIC GUIDANCES FOR THE OFFICE OF PESTICIDES PROGRAMS
23
1. REGION-SPECIFIC PESTICIDE PRIORITY: PESTICIDE OCCUPATIONAL WORKER SAFETY 23
2. REGION-SPECIFIC PESTICIDE PRIORITY: PROMOTE STATE AND TRIBAL PESTICIDE
PROGRAM COORDINATION AND COMMUNICATION 24
3. REGION-SPECIFIC PESTICIDE PRIORITY: BED BUG OUTREACH/ASSISTANCE 25
4. REGION-SPECIFIC PESTICIDE PRIORITY: ENDANGERED SPECIES PROTECTION 26
5. REGION-SPECIFIC PESTICIDE PRIORITY: POLLINATOR PROTECTION OUTREACH 27
6. REGION-SPECIFIC PESTICIDE PRIORITY: SPRAY DRIFT INCIDENT DATA 27
VII. PROGRAM-SPECIFIC GUIDANCE FOR THE OFFICE OF POLLUTION
PREVENTION AND TOXICS 29
COMMUNITY ACTION FOR A RENEWED ENVIRONMENT (CARE) 29
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VII. APPENDIX A: NPM GUIDANCE MEASURES 30
VIII. APPENDIX B: EXPLANATION OF CHANGES BETWEEN FY 2013 AND FY 2014 33
IX. APPENDIX C: KEY PROGRAM CONTACTS 37
X. APPENDIX D: FY 2014 EXTERNAL COMMENTS AND RESPONSE TO COMMENTS
SUMMARY TEMPLATE 38
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I. AGENCY OVERVIEW TO THE FY 2014 NPM GUIDANCES
The FY 2014 NPM Guidances provide a national framework for regional, state, and tribal
implementation of EPA's FY 2014 Annual Plan and Budget and Strategic Plan1 to advance the
Agency's mission. The Overview to the NPM Guidances communicates important agency-wide
information and should be reviewed in conjunction with each of the Final FY 2014 NPM Guidances as
well as other applicable requirements. The Overview also includes important background information
and the eleven cross-program areas that are critical to effective implementation of EPA's environmental
programs in FY 2014. Read the overview at http://www2.epa.gov/planandbudget/fy2014.
II. INTRODUCTION
The Office of Chemical Safety and Pollution Prevention (OCSPP) National Program Manager (NPM)
Guidance for FY 2014 provides direction to the EPA regional offices with respect to the Chemical
Safety (including Pesticides) and Pollution Prevention (P2) programs, incorporating input from states,
tribes and other concerned stakeholders. The Guidance identifies OCSPP's FY 2014 program priorities
for regional offices, summarizes the FY 2014 annual performance plans for each of the national
programs managed by the Office of Pesticide Programs (OPP) and the Office of Pollution Prevention
and Toxics (OPPT), details the specific contributions needed from the regional offices and identifies the
commitments that will be used to hold regional offices accountable for contributing to those program's
goals and objectives. More information on OCSPP can be found at
http://www2.epa.gov/aboutepa/about-office-chemical-safety-and-pollution-prevention-ocspp.
In addition to this guidance, OCSPP is developing a Climate Change Adaptation Implementation Plan in
conjunction with other NPMs, which will be finalized in June 2013. In FY 2014, regional offices and
HQ programs will implement specific priority actions, as appropriate, contained in the OCSPP
Implementation Plan to more fully integrate climate change adaptation planning into its core programs.
III. OCSPP'S NATIONAL AREAS OF FOCUS FOR FY 2014
Pesticides Office Programs
Integrated Pest Management (IPM) in Schools. Increasing adoption of IPM practices in public
schools grades K-12 and ultimately decreasing exposure of children to pests and pesticides.
1 The EPA Strategic Plan is currently being updated for FY 2014-2018 and will be available in February 2014 at the
following website: http://www2.epa.gov/planandbudget/strategicplan.
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Effective Management of State and Tribal Grants/Cooperative Agreements. Ensuring consistency
implementing the FIFRA Grant Guidance, and providing effective oversight and support to our state
and tribal partners so that agency resources are directed to areas where they are most needed and
best support the goals of the National Pesticide Program.
Coordinating with State/Tribal Pesticide Agencies and Regional Water Programs to Obtain
Pesticide Water Quality Monitoring Data. Increasing coordination with state and tribal pesticide
programs and the EPA regional water programs to obtain existing water monitoring data for
consideration in pesticide risk assessments.
Region-Specific Pesticide Priorities. Providing opportunities to select national pesticides priority
areas which best address the needs of individual states and tribes and have the greatest potential
pesticide risk reduction in their area of the country. Regional offices are to select two priority areas
out of the following for special focus and will conduct at least one special project in each area
selected (a total of two special projects): Worker Safety, Promotion of State and Tribal Pesticide
Program Coordination and Communication, Bed Bug Outreach/As si stance. Endangered Species
Protection, Pollinator Protection Outreach, and Spray Drift Incident Data.
Pollution Prevention and Toxics Office Programs
Lead Risk Reduction Program. Eliminating lead poisoning as a public health concern.
Chemical Risk Management Program. Ensuring that no unreasonable risk is posed by chemicals
introduced into U.S. commerce and eliminating or significantly reducing any unreasonable risk they
may pose.
Pollution Prevention Program. Fostering the development of P2 innovations and practices and
promoting the adoption, use and market penetration of those innovations and practices.
The EPA regional offices' annual program commitments and results are reported in the agency's
accountability system, the Annual Commitment System (ACS). OCSPP's suite of ACS commitments is
presented in Appendix A. The FY 2014 regional offices commitments in ACS will remain as draft until
final performance agreements are reached in October 2013. Additional information is appended to this
Guidance: Appendix B identifies the FY 2014 changes in OCSPP's regional offices priorities, strategies
and measures since the release of FY 2013 NPM Guidance. Appendix C provides program contact
information for OPP and OPPT. The agency's responses to public comments received in the draft
version of this Guidance are listed in Appendix D to the Guidance.
More information on the agency's NPM Guidance development process, public comment process, other
NPM Guidances to the regional offices and the agency's official commenting template can be found on
the EPA's planning and budgeting website at http://www2.epa.gov/planandbudget/fy2014. Additional
information on the EPA performance measures, planning and budgeting can be found at
http://www2.epa.gov/planandbudget.
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IV. NATIONAL AREAS OF FOCUS FOR THE OFFICE OF PESTICIDE
PROGRAMS
1. NATIONAL AREA OF FOCUS: SCHOOL INTEGRATED PEST MANAGEMENT (IPM)
A. Description
The EPA recognizes that pest control and pesticide use in areas where children are present poses special
challenges and concerns. Additionally, our nation's children spend a considerable amount of their time
in schools, as do teachers and school support staff. The National Center for Education Statistics
estimates that in 2010, nearly 50 million students attended public elementary and secondary schools,
with enrollment rates steadily increasing every year. With this in mind, the agency is pursuing a program
to encourage school officials to adopt integrated pest management (IPM) practices as a means to reduce
exposure to, and risk from pests and pesticides in schools and on school grounds. The initial focus of
this program is public schools at the elementary through secondary levels (grades K-12). The goal of
this activity is to decrease exposure of children in public schools (grades K-12) to pests and pesticides
through increased adoption of verifiable and ongoing IPM programs. More information can be found at
http://www.epa.gov/pesticides/ipm/.
Activities to support School IPM support Goal 4 of the agency's Strategic Plan by protecting human
health from pesticide risk. This activity also supports the agency's children's health goals. See the
approaches and regional roles and responsibilities listed in the agency's "Strategic and Implementation
Plans for School Integrated Pest Management: Federal Fiscal Years 2012-2014 (Sept. 6, 2012)," found
at http://www.epa.gov/pestwise/ipminschools/strategicplan.pdf.
B. Regional Activities
The EPA will generally focus resources on "wholesale" approaches designed to provide information
and create a demand for school IPM as efficiently as possible (e.g., coordinating with other agency
school programs, focusing outreach efforts to large groups and organizations and trying to impact
the largest number of school children in the shortest amount of time with the least investment of
time/resources).
Regional offices may also pursue "retail" approaches (direct technical assistance to schools) to a
small degree in order to maintain technical expertise and contact with school IPM implementation
issues.
C. Measure
(ACS Code: IPM2) Number of activities conducted, consistent with the EPA's "Strategic and
Implementation Plan for School Integrated Pest Management," to provide outreach, education,
and/or assistance to public schools at the kindergarten through high school levels to adopt verifiable
and sustainable IPM practices.
This measure is a non-commitment measure for FY 2014.
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Regional offices must provide a brief description and the number of each type of activity that were
conducted in their region in the comment field during mid- and end-of-year ACS reporting.
Activities are defined as substantial increments of work with one or more internal or external
stakeholder(s) or development of program capacity such as databases or educational resources to
advance IPM in schools. In order to keep a wide range of activities somewhat comparable, each
reported activity should generally include 1) preparation, 2) substantive participation and 3) follow-
up actions, as needed.
2. NATIONAL AREA OF FOCUS: STRENGTHENING STATE/TRIBAL PARTNERSHIPS
THROUGH CONTINUED EFFECTIVE MANAGEMENT OF GRANTS/ COOPERATIVE
AGREEMENTS
A. Description
The National Pesticide Program depends on cooperative agreements with states and tribes to implement
many of the requirements of Federal Insecticide, Fungicide, and Rodenticide Act Cooperative
Agreement (FIFRA) and to help ensure our regulatory decisions and programs achieve intended
protections. OPP, OECA and the EPA Regions all have an important role in effective management of
these grants and cooperative agreements. Regional offices are responsible for negotiating, implementing
and managing state and tribal cooperative agreements and grants consistent with the joint OPP/OECA
FIFRA Grant Guidance. EPA grants provide resources to carry out many of the activities required in the
FIFRA Cooperative Agreements. Regional offices provide oversight to grantees to assure resources are
directed to areas where they are most needed, that grantees conduct meaningful work in priority areas
and that grantees meet their grant and cooperative agreement responsibilities. The regional offices, with
the support of OPP and OECA, are also expected to provide technical and program support to the
grantees to help them be successful in meeting their grant commitments. Regional offices are uniquely
positioned to provide this oversight and support given their proximity and working relationships with
states and tribes. More information on the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
State and Tribal Assistance Grant (STAG) Program can be found at
http://epa.gov/compliance/state/grants/fifra.html.
B. Regional Activities
Negotiating state and tribal cooperative agreements and workplans consistent with the FIFRA Grant
Guidance.
Issuing grant funds to states and tribes in a timely manner once they become available and/or
consistent with the start of the cooperative agreement funding period (unless another timeframe is
negotiated with the grantee).
Ensuring end-of-year reporting consistent with the mechanisms, quality and timeframes listed in the
FIFRA Grant Guidance.
Fostering prompt and accurate communication of EPA Pesticide Program regulations, policies and
guidance to grantees.
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Providing effective technical assistance and policy support for the grantees on national pesticide
priorities listed in the FIFRA Grant Guidance (e.g., evaluation and management of pesticides in
water, endangered species protection, implementation of container/containment requirements,
worker safety).
C. Measure
(ACS Code: CORE) Percent of overall required pesticide program cooperative agreement activities
that are included in grantee workplans and completed consistent with the pesticide program portion
of the FIFRA Grant Guidance.
Commitment target is 100%. (Percent of pesticide program required activities completed by grantee
as compared to the total required by pesticide program portion of the FIFRA Grant Guidance.)
This measure is intended to show that regional offices included required pesticide program activities
in grantee workplans and conducted the oversight and technical support needed to help grantees
successfully complete those activities. This measure focuses on activities required by the FIFRA
Grant Guidance because it is those activities that are considered essential to maintaining a baseline
operation of a program area, achieving environmental results and helping support national
performance measures (including providing data related to those measures). While those activities
designated as required in the FIFRA Grant Guidance must appear in cooperative agreements, the
level of effort and resources devoted may be negotiated depending on specific needs and priorities of
states and tribes.
Since end-of-year reports for these cooperative agreements are not due to OPP from the regional
offices until February 28, 2015, data for this ACS measure will not be available at the end of the
fiscal year for reporting into ACS. When regional offices report their ACS measures at the end of the
fiscal year, they may indicate in the comment field for this measure that this data will not be
available until February/March and will be reported at that time.
This measure also recognizes there may be legitimate unanticipated reasons, such as unexpected loss
of staff or technical expertise or unforeseen emergencies, which may prevent grantees from
completing core workplan requirements. Under these circumstances, regional offices may agree to
temporarily modify required activities originally included in the workplan. Required activities
modified or not completed due to legitimate unanticipated reasons can be removed from the total
required if a reasonable rationale is documented (e.g., unexpected loss of staff or unplanned crises
during the project period).
3. NATIONAL AREA OF FOCUS: COORDINATING WITH STATE/TRIBAL PESTICIDE
AGENCIES AND REGIONAL WATER PROGRAMS TO OBTAIN PESTICIDE WATER
QUALITY MONITORING DATA
A. Description
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An important goal of the pesticide registration review process is to resolve water quality issues related to
the use of pesticides and to reduce the potential for future issues to arise. Easy access to and
consideration of existing water monitoring data can help OPP characterize pesticide exposures to water
resources, design effective risk mitigation and evaluate whether risk mitigation has been achieved.
Effectively addressing pesticide water quality concerns through the pesticide registration review process
reduces the need for the other EPA programs and state/tribal pesticide and water programs to use their
limited resources to address pesticide impaired waters under the Clean Water Act (CWA), and more
efficiently protect human health and the environment from pesticide risks. Regional pesticide offices can
help OPP locate and collect existing water monitoring data for pesticides that are undergoing
Registration Review by coordinating with state/tribal pesticide agencies and the regional water program
offices to obtain water monitoring data that is not already available in the agency's STORET (short for
STOrage and RETrieval) Data Warehouse, Pesticide of Interest Tracking System (POINTS), or other
data sources readily accessible to OPP.
Activities to support this priority help support Goal 4 of the agency's Strategic Plan by protecting human
health and the environment from pesticide risk, and also support the goal of reducing the concentration
of pesticides in urban and agricultural watersheds.
B. Regional Activities
For registration review cases identified by OPP, routinely coordinate with state and tribal pesticide
agencies, the EPA regional water offices, or other EPA regional media programs (e.g., Great Lakes
and Chesapeake Bay) to locate water monitoring data that are not already available in the agency's
STORET data warehouse or otherwise available to OPP. Any data obtained through this process
will be submitted to OPP staff.
Work with state and tribal pesticide agencies, the EPA regional water offices, or other EPA regional
media programs (e.g., Great Lakes and Chesapeake Bay) to locate water monitoring data sources
that contain data not already entered into the agency's STORET data warehouse or otherwise
available to OPP. If these data sources are located, regional offices will help make those sources
available to OPP.
Consider establishing relationships with state, tribal and local agencies, water monitoring
organizations and other stakeholder groups within the region to stay abreast of new water monitoring
data sources.
Regional offices, states and tribes with available data for submission for specific active ingredients can
consult the Water Quality Data Submissions: OPP Standard Operating Procedures at
http://www.epa.gov/oppsrrdl/registration review/water quality sop.htm for guidance.
C. Measure
No ACS measures are proposed to be associated with this area of focus for FY 2014.
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4. NATIONAL AREA OF FOCUS: REGION-SPECIFIC PESTICIDE PRIORITIES
A. Description
Regional offices are to select two priority areas out of the Region-Specific Pesticide Priority list
provided below for special focus and will conduct at least one special project in each area selected (a
total of two special projects). Regional offices must ensure that they propose substantive projects for
each priority area selected. Each of these Region-Specific Pesticide Priority areas: 1) supports one or
more of the agency's Strategic Plan goals and strategies, 2) are priorities for the National Pesticide
Program, 3) have significant headquarters resource investment, and 4) have a clear potential for regional
office involvement. However, we also recognize that the relative priority of each of these program areas
will vary across the country. Therefore, this national focus area enables regional offices to select priority
areas which best address the needs of their states, tribes and vulnerable populations, and will likely
result in the greatest reduction of potential pesticide risk in their area of the country.
It is important to note that while each regional office is not required to conduct a project in each
program area, regional activities will likely still be needed in program areas not selected in order to
oversee and support cooperative agreements, FIFRA Grant Guidance, statutory and regulatory
requirements, or respond to public inquiries. In addition, there will also be work to support other
Pesticide Program areas and issues, such as the Antimicrobial Testing Program (ATP),
container/containment rule implementation and implementation of the new soil fumigation
requirements; however, the level of effort associated with program related work in these areas (e.g.,
technical assistance and outreach) will be more routine in nature or may be more related to enforcement
activities covered in the OECA NPM Guidance.
Region-Specific Pesticide Priority areas to choose from are:
(l)Pesticide Occupational Worker Safety;
(2)Promote State and Tribal Pesticide Program Coordination and Communication;
(3)Bed Bug Outreach/Assistance;
(4)Endangered Species Protection;
(5)Pollinator Protection Outreach; and
(6)Spray Drift Incident Data.
Details of these Region-Specific Pesticide Priority areas can be found in the Program-Specific Guidance
in the Section IV of this Guidance.
The following should be considered to assure robust and substantive special projects for the two
program areas selected:
Each regional office must conduct projects in at least two of the Region-Specific Pesticide Priority
areas.
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Projects must be designed to enhance the stated goals of the program area selected by the regional
office and show meaningful results.
Projects may entail outreach, education, training, stakeholder coordination, program evaluation, state
or tribal program capacity building and support, or other similar project/initiatives that may lead to
program improvement.
Proposals for projects should include a clear statement of what work will be done, what the project
hopes to accomplish and how the project will support the goals of the program areas.
Regional offices are encouraged to set ambitious goals that result in true protections.
To help ensure robust projects, OPP and the regional offices will review and discuss proposed
projects prior to initiating work.
Projects may be designed to be completed in one to three years. Multi-year projects should have
measurable milestones for each year of the project. Regions that are completing a multi-year NPM
project from a previous fiscal year may count that project as one of their two NPM projects in FY
2014 even if the program area is no longer a priority in FY 2014.
Projects (or one phase of a multi-year project) must be completed by the end of the fiscal year.
Regional offices must submit project reports to OPP within 30 days of the end of the federal fiscal
year.
The results of each project will be reviewed by OPP and regional offices at the end of the fiscal year
and discussed on a conference call or meeting so that innovations and lessons learned may be shared
across the regional offices and pesticide program.
Project results will be compiled for National Pesticide Program Accomplishments reports.
B. Regional Activities
Conduct two special projects to support two different Region-Specific Pesticide Priority areas. Projects
should meet the guidelines described above to assure robust and substantive projects.
C. Measure
(ACS Code: RSP2) Number of region-specific projects or initiatives contributing to the
implementation and enhancement of the region-specific pesticide program priority areas.
Commitment target is two projects or initiatives (one from each Region-Specific Pesticide Priority
area selected by the region).
Regional offices should report their selection of program areas in the comment field for the ACS
measure RSP2, entitled "Number of region-specific projects or initiatives contributing to the
implementation and enhancement of the Region-Specific Pesticide Priority areas."
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V. NATIONAL AREAS OF FOCUS FOR THE OFFICE OF POLLUTION
PREVENTION AND TOXICS
1. NATIONAL AREA OF FOCUS: LEAD RISK REDUCTION PROGRAM
A. Description
Recent data show significant progress in the continuing effort to eliminate childhood lead poisoning as a
public health concern. Results of recent studies, however, indicate adverse health effects to children at
extremely low blood levels, below 10 micrograms per deciliter. In response to this new information and
the fact that approximately 38 million homes in the U.S. still have lead-based paint, EPA is targeting
reductions in the number of children with blood lead levels of 5 micrograms per deciliter or higher.
Additionally, the Lead Program tracks the disparities in blood lead levels between low-income children
and non-low-income children. The program uses a performance measure to track progress toward
reducing the differential severity of childhood lead poisoning in vulnerable populations. The EPA's
long-term goal, as reflected in the Fiscal Year 2011-2015 EPA Strategic Plan, is to close the gap
between the geometric mean blood lead levels among low-income children versus non-low-income
children, from a baseline percentage difference of 45.7 percent (1999-2002) to a difference of 20 percent
by FY 2014.
The Lead Risk Reduction Program, including its Categorical Grant component, contributes to the goal of
eliminating childhood lead poisoning by: establishing standards governing lead hazard identification
and abatement practices and maintaining a national pool of professionals trained and certified to
implement those standards; providing information to housing occupants so they can make informed
decisions and take actions about lead hazards in their homes; and, establishing and maintaining a
national pool of certified firms and individuals who are trained to carry-out renovation, repair and
painting projects while adhering to the lead-safe work practice standards and to minimize lead dust
hazards created in the course of such projects.
The Lead Risk Reduction Program is an important contributor to the agency's cross-cutting priorities to
protect children's health, advance environmental justice and improve health on tribal lands. The
Program's outcome measures described above compel us to focus our resources to the maximum extent
practicable on eliminating childhood lead poisoning in the most vulnerable populations of children.
Regional offices are directed to obligate 100% of FY 2014 and any prior years' unobligated Lead
Categorical Grant funds by June 30, 2014. This accelerated time frame, agreed to at the October, 2012
OCSPP Regional Division Directors Meeting, will facilitate redirection of unobligated funds to ensure
obligation by the end of the fiscal year. OCSPP recognizes that some aspects of the obligation process
are beyond the direct control of regional office Lead program managers and staff; such issues can be
addressed in explanations required to be provided for delayed obligations.
More information can be found at http://www.epa.gov/lead. The Lead Risk Reduction Program's FY
2014 Activities and Performance Plan proposed in EPA's FY 2014 President's Budget can be found at
http://www.epa.gov/planandbudget/.
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B. Regional Activities
Regional offices should fully implement the first seven Lead Program activities outlined below and may
choose to implement one or more of the last six activities. All regional offices are required to inform
OPPT's National Program Chemicals Division of their selections among these optional activities in
conjunction with their entry of their initial ACS commitment bids. Consistent with the agency's
initiatives on Environmental Justice (EJ), the selected proposed lead activities should also look for ways
to address EJ concerns and incorporate community engagement where feasible.
Regional offices should fully implement the Lead Program activities outlined below:
Section 404(g) Grant Program Management: Regional offices should manage the 404(g) grant
program in accordance with the annual Section 404(g) grant guidance document.
Outreach for Lead Rules: Regional offices should provide outreach for Pre-Renovation Education
Rule (406), the Lead Abatement Rule (402(a)), the Renovation, Repair and Painting Rule (402(c))
and, to a limited extent, the Disclosure Rule (1018).
Renovation, Repair and Painting Rule (RRP) (402(c)) Implementation: Regional offices should
assist in the implementation of the RRP Rule by accrediting qualified training providers and
providing information and compliance assistance to the regulated community.
Lead-based Paint Activities Rule (402(a)) (Abatement, Risk Assessment and Inspection)
Implementation: Regional offices should assist in the implementation of the Lead-based Paint
Activities (Abatement, Risk Assessment and Inspection) Rule by accrediting qualified training
providers, certifying individuals and by providing information and compliance assistance to the
regulated community.
Encourage State and Tribal RRP Program Authorization: Regional offices should collaborate with
their states and/or tribes to encourage them to become authorized to run the RRP Program. Regional
offices should provide information regarding the benefits of the Program, identify roadblocks to
RRP authorization, gain knowledge about the states or tribes' needs to run the program and identify
potential solutions.
Lead Program Coordination with OECA: Regional offices should coordinate implementation of the
full suite of Lead Program regulations and activities as expressed in OECA's TSCA Compliance
Monitoring Strategy including compliance assistance, monitoring and enforcement strategies that
can be found at http://www.epa.gov/oecaerth/monitoring/programs/tsca/index.html.which can be
found at http://www.epa.gov/oecaerth/monitoring/programs/tsca/index.html.
Outreach to Renovators and Homeowners: Regional offices should provide information on the
hazards of renovation activities in homes with lead-based paint. This outreach should stress the
importance of using a EPA Lead-Safe Certified firm and the benefits of following lead safe work
practices. Outreach should target homeowners and renters in areas with older housing, vulnerable
populations and renovation firms.
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Regional offices may also choose to implement one or more of the Lead Program activities below:
Engagement with State/City Permitting and Licensing Officials: Regional offices could work with
permitting and licensing offices to require that firms have shown proof of RRP certification prior to
permits being issued. Because of the strong and direct connection between licensing and permitting
offices and the construction industry, this is especially valuable in supporting implementation of the
RRP Rule.
Partner with Tribes: Regional offices could create opportunities for partnerships with their Tribes to
address lead-based paint hazards and exposure reduction including Direct Implementation Tribal
Cooperative Agreements (DITCAs) and Memoranda of Understandings. Regional offices could
partner with Tribes to identify projects, DITCA-related activities or ongoing projects to reach the
national goal of eliminating childhood lead poisonings.
Partner with Child-focused Stakeholders to Educate about RRP: Regional offices could partner
with federal, state and local organizations, child care providers and child-focused entities to develop
outreach strategies that stress the importance of using an EPA Lead-Safe Certified firm and the
benefits of following lead safe work practices. Outreach should target homeowners and renters in
areas with older housing, vulnerable populations and renovation firms. These partnerships can also
focus on increasing public awareness about preventing childhood lead poisoning, particularly among
low-income and other vulnerable populations.
Partner with Public Health Community to Educate about RRP: Regional offices could perform
outreach to the public health community, including pediatric organizations, doctor offices, hospitals
and other medical facilities to increase public awareness about the hazards and prevention of
childhood lead poisoning. Regional offices could provide information on the importance of using an
EPA Lead-Safe Certified firm.
Partner with States for Lead Education and Outreach: Regional offices could partner with their
states to conduct lead-based paint risk reduction education and outreach in areas with high
concentrations of children with elevated blood levels.
Collaborate with other Federal Agencies: Regional offices could create opportunities for
partnerships with other Federal agencies and work with them to gain access or knowledge about
activities other Federal agencies are conducting in tribal or EJ communities and reach the national
goal of eliminating childhood lead poisonings.
C. Measures
(ACS Code: 13A) Annual percentage of viable lead-based paint abatement certification applications
that require less than 20 days of EPA regional office effort to process (Direct Implementation).
This measure directly supports the Government Performance and Results Act (GPRA) annual budget
performance measure.
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ACS measure 13A examines the efficiency of those regional offices as they process viable individual
abatement certification applications for those regional offices that will be processing the
certifications on behalf of all regional offices.
In FY2014, the Federal Lead-based Paint Program (FLPP) database is expected to be amended to
accommodate the change in certification processing and the delegation of authority is anticipated to
be revised by the start of FY2014. Following these two changes, HQ will ensure that the regional
offices that will not be processing abatement certifications will not have to report in ACS. If ACS
changes are not approved, the regional offices that are not processing abatement certifications
should report 100% and write the following statement in the comment field: "In FY2014, Region
XX is processing the certifications for the regional office."
If by FY2014, the changes in FLPP are not ready, then regional offices will continue to use the
following procedures: ACS Measure 13A is calculated by using two timeframes. Timeframe 1 is the
number of days elapsed from the "Sent to Regional Office" date (when the contractor sends the
application to the regional office) to the "Regional Office Review" date (when the regional office
enters its recommendation to approve/disapprove.) Timeframe 2 is the number of days from the
"Approval or Disapproval Letter Generated" date entered by the regional office to the "Final
Package Sent" date entered by the regional office. Timeframes 1 and 2 are added together to give the
total processing time.
The two timeframes do not include time from any other 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.
Example: If a final package is mailed to an applicant on September 1, and then two weeks later (on
September 15) the regional office staff enters FLPP to update the database, and clicks the "Final
Package Sent" button for that application, the September 15 date is entered into FLPP as the date the
final package was sent (rather than the actual September 1 date). Please note, this cannot be
overridden, so be certain to enter your progress on the day that you accomplish each action.
(ACS Code: 13B) Annual percentage of viable lead-based paint abatement certification applications
that require less than grantee state-established timeframes to process.
ACS measure 13B examines the efficiency of authorized Grantee-States as they process viable
abatement certification applications within the Grantee-State established timeframes.
Each regional office should ensure that states can achieve the minimum planning target. 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 Grantee-State and represented to the
public.
The regional offices should use the ACS comment field to report the number of applications
processed by Grantee-State, Grantee-State timeframes (number of days taken to process a viable
application) for each shareholder (state or tribe) and the percentage of applications processed under
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the Grantee-State established timeframe. The timeframe may vary by state, taking variables such as
regulations and contractor processing time into account.
(ACS Code: 14) Number of lead abatements performed by certified abatement contractors occurring
in the region.
ACS measure 14 is a non-commitment 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.
Regional offices should only count the number of abatement notifications received in the fiscal year
in order to accurately assess the number of abatement activities being done in the regional offices.
(ACS Code: RRP2) Number of active lead-based paint renovation, repair and painting certification
training providers accredited by the regional office.
ACS measure RRP2 is a non-commitment measure, which captures the number of training providers
for lead-based paint Renovation, Repair and Painting (RRP) Rule with active accreditations
processed by the regional office. Regional offices should only count the RRP trainers where EPA
runs the program; they should not count RRP trainers in states where there is a state authorized
program. Regional offices should count the number of current accredited trainers whose
accreditations were processed by that regional office by September 2014, the last working day of the
fiscal year.
This measure does not count the number of accredited training courses. It also does not measure the
nation's capacity for training, but rather the workload of the regional offices in accrediting trainers.
(ACS Code: TR-1) Number of tribal partnerships or projects addressing lead-based paint hazards
and exposure reduction in the region.
ACS measure TR-1 is a 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 subset of overall lead projects or 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.
2. NATIONAL AREA OF FOCUS: CHEMICAL RISK MANAGEMENT PROGRAM
A. Description
The Chemical Risk Management (CRM) Program supports national efforts aimed at mitigating chemical
risk and exposure through reductions in use and safe removal, disposal and containment of certain
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prevalent, high-risk chemicals - known generally as legacy chemicals. Some of these chemicals were
widely used in commerce and introduced into the environment before their risks were known. In FY
2014, the CRM Program will primarily focus on providing assistance to federal agencies, states, tribes,
local governments, school systems and others with responsibility to ensure proper use of polychlorinated
biphenyls (PCBs) and limiting exposures to PCBs, and secondarily, encouraging the use of alternatives
to mercury-containing products.
The Chemical Risk Management Program augments OCSPP's Chemical Risk Review and Reduction
Program, which works to ensure the safety of:
new chemical, by reviewing and acting on new chemical notices submitted by industry to ensure that
no unreasonable risk is posed when those chemicals are introduced into U.S. commerce; and
existing chemicals, by obtaining and making public needed data, assessing those data and taking
regulatory and non-regulatory actions to eliminate or significantly reduce any unreasonable risk they
may pose .
Work related to the rulemaking to reassess the ongoing authorized uses of PCBs to determine whether
certain use authorizations should be ended or phased out is being developed under the Chemical Risk
Review and Reduction Program. The Chemical Risk Review and Reduction Program is not addressed in
the NPM Guidance because no resources are allocated to regional offices under that program.
The Chemical Risk Management Program's FY 2014 Activities and Performance Plan proposed in
EPA's FY 2014 President's Budget can be found at http://www.epa.gov/planandbudget/.
B. Regional Activities
Regional offices should accomplish, or make substantial additional progress toward accomplishing, at
least one of the proposed CRM Program activities identified below in the PCBs category, and are
encouraged to also undertake work described under the Mercury category. In the event that the priority
PCBs work is accomplished and regional offices do not elect to perform work related to mercury use
reductions, regional offices may elect to address other chemicals of concern as well, where limited
resources make this work possible, after consultation with OPPT. All regional offices are required to
inform OPPT's National Program Chemicals Division (NPCD) of their selections among these activities
in conjunction with their entry of their initial ACS Commitment bids. Many of these activities focus on
school environments. As such, the CRM Program provides regional offices with significant
opportunities to advance EPA's cross-cutting priorities to protect children's health, advance
environmental justice, improve community health and improve health on Tribal lands.
Polychlorinated Biphenyls (PCBs)
Outreach Regarding PCBs in Fluorescent Light Ballasts: Regional offices could perform outreach
to their State's Department of Education, school districts, schools and child care providers regarding
PCBs in fluorescent light ballasts, caulk and/or paint. Outreach activities could include, but not be
limited to letters, fact sheets, webinars, technical assistance to schools performing work, etc., and
follow-up education.
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Outreach and Assistance to Schools: Regional offices could continue to provide assistance and
promote education and outreach efforts on PCBs in caulk and/or paint in schools and other buildings.
Partner with Stakeholders for PCB Ballast Reduction: Regional offices could partner with their
State's Departments of Education, Energy, Health and State-run Utilities to educate and identify
stakeholder incentives (e.g., grants, loans, ESCOs, etc.) to help address the removal of PCB-
containing fluorescent light ballasts in schools. A regional office could work with their State's
Departments of Environment and Health to provide outreach and identify incentives to State's
Departments of Education and interested districts and schools.
Phase-out PCB Transformers: Regional offices could perform outreach work with PCB transformer
owners (e.g., utilities, industrial facilities) to evaluate PCB transformer presence against the OPPT
transformer database, identify pollution prevention and waste minimization opportunities, and
discover utility incentives for transformer owners to take the transformers out of service and replace
them with non-toxic transformers (vegetable oil or FR3TM fluid).
Mercury
Outreach to Reduce Mercury-containing Equipment in Industrial Facilities: Regional offices could
work with their states to develop guidance and materials for outreach to industrial facilities to assist
them with upgrades, removal, and/or proper disposal of mercury-containing equipment. The
outreach and material development should be coordinated with CERCLA/Brownfields Assessments,
RCRA site visits, or other EPA/state permitting practices as an implementation/engagement tool.
Facilitate Mercury Reduction Project: Regional offices could facilitate or assist in the removal of
mercury-containing equipment through support of and cooperation with various state and
environmental non-government organization mercury reduction projects.
C. Measures
(ACS Code: TSCA1) Number of activities conducted to reduce or prevent exposure to chemicals of
concern, with a focus on PCBs.
Measure TSCA1 is a non-commitment measure in its second year and with newly identified
activities with the intent of establishing a baseline to support future commitment development. The
measure seeks to capture the number of activities undertaken by the regional offices to mitigate
chemical risk and exposures to chemicals commonly known as legacy chemicals.
Regional offices, in the ACS Comment Field, will name the specific subset and activities they
conducted that contributes to this measure during the mid-year and end-of-year reporting, including
annotation of all Tribal, EJ & Children's Health efforts. Each regional office should only count the
number of activities that were conducted by that regional office in the fiscal year to accurately assess
the number of activities being done in the regional offices.
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3. NATIONAL AREA OF FOCUS: POLLUTION PREVENTION PROGRAM
A. Description
The Pollution Prevention (P2) Program is one of the EPA's primary tools for advancing environmental
stewardship by federal, state and tribal governments; businesses; communities and individuals. The P2
Program seeks to alleviate environmental problems by achieving significant reductions in the use of
hazardous materials, energy and water; reductions in the generation of greenhouse gases; cost savings;
and increases in the use of safer chemicals and products. This is accomplished by 1) fostering the
development of P2 innovations; and 2) promoting the use, adoption and market penetration of these P2
innovations.
Focusing efforts on environmental issues in specific sectors, geographic areas or for specific chemicals,
the P2 Program accomplishes its mission by: encouraging cleaner production processes and
technologies; promoting development and use of safer, "greener" materials and products; and supporting
implementation of improved practices, such as conservation techniques and reuse and remanufacturing
of hazardous secondary materials in lieu of their discard, including offsite reuse/remanufacturing under
appropriate conditions. These efforts advance the agency's priorities to pursue sustainability, take action
on climate change and reduce chemical risks.
Specifically, regional offices should focus on: expanding the Economy, Energy and Environment (E3)
program; promoting development and use of safer, "greener" materials, chemicals and products,
including Design for the Environment (DfE) labeled products; and providing information, technical
assistance and training to manufacturing and other sectors (such as the Pollution Prevention Resource
Exchange (P2Rx) Centers' efforts to promote greener professional and collegiate level sports activities
and to encourage more sustainable behavior by the sporting industry, its stakeholders, communities and
sports fans).
With respect to sustainability, OCSPP and Office of Solid Waste and Emergency Response (OSWER)
will continue to pursue alignment in this work and other ongoing EPA sustainability approaches, and
will maintain existing or adopt new ACS commitments as needed that will capture the progress achieved
in those areas.
The P2 Program is supported by Environmental Programs and Management (EPM) and State and Tribal
Assistance Grants (STAG) resources in the EPA headquarters and the regional offices. Regional offices
should ensure that businesses are the ultimate beneficiaries of P2 STAG grants. This restriction does not
apply to EPM Source Reduction Assistance (SRA) grants.
Regional offices are directed to make their best effort to obligate 100 percent of FY 2014 and any prior
years' unobligated Pollution Prevention STAG Grant funds by June 30, 2014. This accelerated time
frame, agreed to at the October 2012 OCSPP Regional Division Directors Meeting, will facilitate
redirection of unobligated funds to ensure obligation by the end of the fiscal year. OCSPP recognizes
that some aspects of the obligation process are beyond the direct control of regional office P2 program
managers and staff; such issues can be addressed in required explanations for delayed obligations.
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For more information about EPA's Pollution Prevention Program can be found at
http://www.epa. gov/p2/.
B. Regional Activities
Regional offices should administer their activities in ways that contribute significantly to the agency
achieving its P2 strategic targets.
Foster the Development of P2 Innovations:
Provide Technical Input on Green Products or Practices: Regional offices are encouraged to assist
Headquarters in developing green standards or policies or safer/"greener" materials and products by
providing technical input to federal, state and local level regulatory development work or by creating
or providing technical input on green chemistry and engineering guidance for industry sectors.
Provide Education and Outreach within Educational Systems to Foster Development of Green
Products or Practices: Regional offices are encouraged to provide education and outreach within
educational systems, including enhancing partnerships with universities/colleges to develop curricula
for science, engineering, business, entrepreneurial and other programs to foster development of
green products and practices. Source Reduction Assistance (SRA) grants and direct resources are the
preferred mechanism for this approach.
Promote the Use, Adoption and Market Penetration of P2 Innovations:
Establish Economy, Energy and Environment (E3) Partnerships: Regional offices are encouraged to
establish E3 partnership projects in conjunction with ongoing efforts involving the Departments of
Agriculture, Commerce, Energy, and Labor, and the Small Business Administration in additional
communities to promote sustainable manufacturing and/or agricultural practices and processes by
leveraging and engaging with state, local, and federal partners and providing technical assistance.
Provide Technical Assistance on Green Sports: Regional offices are encouraged to leverage
resources, engage with partners, provide technical assistance and share information to promote
greener professional and collegiate level sports activities and to encourage more sustainable behavior
by the sporting industry, its stakeholders, communities and sports fans.
Provide Technical Assistance for Manufacturing and Other Business Sectors: Regional offices are
encouraged to provide technical assistance to manufacturing and other business sectors (meeting
needs of their region/communities) to achieve reductions in hazardous materials, hazardous
pollution, greenhouse gas emissions and water use.
Promote Environmentally Preferable Practices in the Purchase, Use and Disposal of Electronics:
Regional offices are asked to encourage federal agencies to purchase, use and dispose of electronic
products in an environmentally responsible way.
Integrate Sustainability: Regional offices are encouraged to integrate P2 aspects of sustainability
into EPA and other federal programs.
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Promote Safer, "Greener" Materials, Chemicals and Products: Regional offices are asked to help
improve recognition and use of safer, "greener" materials, chemicals and products, including Design
for the Environment (DfE) labeled products by working with key stakeholders (including
industrial/institutional and consumer groups) to raise awareness of the benefits of safer chemical
products, including how to write and use procurement standards that include chemical safety criteria
and chemical disclosure.
Promote Green Chemistry as aP2 Solution: Regional offices are asked to help enhance existing
partnerships (public-public or public-private) to leverage existing P2 solutions identified through the
Green Chemistry Presidential Challenge Program and the Green Engineering Program, including
enhancing market opportunities for Green Chemistry as a P2 solution.
Participate in and support National Pollution Prevention Information Exchange: Regional offices
are encouraged to work closely with their Technical Assistance Providers and Pollution Prevention
Resource Exchange Centers.
C. Measures
Regional offices should enter their measurement results in the P2 GrantsPlus database. Regional offices
are encouraged, but not required, to use P2 Calculators - the Greenhouse Gas Reductions Calculator, the
P2 Cost Savings Calculator and the Gallon-to-Pounds Conversion Calculator - in calculating
measurement results. More information on these calculators and other information on P2 measurement
can be found at http://www.epa.gov/p2/pubs/resources/measurement.html.
(ACS Code: 262) Gallons of water reduced through pollution prevention.
This measure directly supports the GPRA annual budget performance measure.
ACS measure 262 is a commitment measure that counts the gallons of water reduced as a result of
water conservation. The initial reduced use of water is what is counted. This can be accomplished
through conservation and re-use of water.
(ACS Code: 263) Business, institutional and government costs reduced through pollution prevention.
This measure directly supports the GPRA annual budget performance measure.
ACS measure 263 is a commitment measure that counts the amount of money saved from
incorporating pollution prevention practices into the daily operations of government agencies,
businesses and institutions.
Under P2 STAG grants, only the cost savings to businesses can be counted.
Regional offices should use the measurement methodology section of P2 GrantsPlus to state all
known factors contributing to cost savings, whether they are factors captured in the Program's P2
Cost Savings Calculator or not.
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(ACS Code: 264) Pounds of hazardous material reduced through pollution prevention.
This measure directly supports the GPRA annual budget performance measure.
ACS measure 264 is a commitment measure that counts the reduction of hazardous substances,
pollutants, or contaminants released to air, water, land, 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 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.
The P2 Program considers the reuse of materials as source reduction when the materials still have
value and have not been discarded. Reuse of hazardous materials allows for annual reporting of
associated life-cycle benefits in reducing virgin hazardous material use and hazardous releases,
greenhouse gas emissions, water use, and costs.
Reducing nonhazardous materials at the source cannot serve as a primary purpose of a grant
associated benefits. If use reduction, reuse or recycling of nonhazardous materials occurs as an
ancillary activity under the grant, this does allow regional offices to report associated annual
reductions in greenhouse gas emissions. These greenhouse gas emission reductions would otherwise
go unreported and the "metric tons of carbon dioxide equivalent (MTCO2e) reduced or offset"
measure is defined broadly and without hazardous material limitations.
(ACS Code: 297) Metric tons of carbon dioxide equivalent (MTCO2e) reduced or offset through
pollution prevention.
This measure directly supports the GPRA annual budget performance measure.
ACS measure 297 is a commitment measure that counts the metric tons of carbon dioxide equivalent
(MTCO2e) reduced or offset.
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VL PROGRAM-SPECIFIC GUIDANCES FOR THE OFFICE OF PESTICIDES
PROGRAMS
The following six Program-Specific Guidances for the Office of Pesticides provides additional guidance
to support the Region-Specific Pesticide Priorities listed previously in the National Area of Focus:
Region-Specific Pesticide Priorities in Section III.4 of this NPM Guidance. Regional offices are to select
two priority areas out of the Region-Specific Pesticide Priority list for special focus and will conduct at
least one special project in each area selected (a total of two special projects).
1. REGION-SPECIFIC PESTICIDE PRIORITY: PESTICIDE OCCUPATIONAL WORKER
SAFETY
A. Description
Ensuring effective implementation of the agency's pesticide worker safety program remains a high
priority for OPP and is important to the agency's overall strategy to ensure chemical safety, prevent
pollution, advance environmental justice and protect children's health. Additional information of the
pesticide Worker Protection Standard (WPS) Program can be found at
http://epa.gov/pesticides/health/worker.htm.
The principal worker safety program activities in FY 2014 will be to continue efforts to ensure effective
implementation of the existing WPS and Certification and Training (C&T) rule requirements, and to
complete the agency's efforts to propose modifications, improvements and enhancements to the WPS
and C&T rules. Effective field implementation of agency's pesticide worker safety program relies on
regional offices collaborating with states, tribes, other federal agencies, industry groups, trade
organizations, advocacy groups, community-based organizations, the regulated community and other
program stakeholders to develop the array of partnerships that advance worker safety and contribute to
successful field implementation of the worker safety program.
Activities to support worker safety and the competence of pesticide applicators are key contributors to
Goal 4 of the agency's Strategic Plan by protecting human health and the environment from pesticide
risk. The pesticide worker safety NPM priority area is also a key part of OPP's overall work to support
the agency's EJ Plan 2014. The WPS program is critical to assuring that agricultural farmworkers,
which represent some of the most economically disadvantaged people in the U.S., are protected from
occupational pesticide hazards, and it is also a key component of OPP's EJ activities. Regional
activities, such as outreach and education efforts to this EJ community, are important to help protect this
vulnerable population from occupational pesticide hazards and ensure their safety in the workplace.
B. Regional Activities
Regional offices emphasizing this area must conduct at least one region-specific project/initiative
contributing to implementation/enhancement of the WPS and/or C&T field programs, or mitigation of
other occupational pesticide exposure risks. All projects should have particular emphasis on addressing
EJ concerns and incorporate community engagement where feasible.
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The goal of a WPS project should be enhanced protection of agricultural pesticide workers and
handlers.
The goal of a C&T project should be improved competency of certified pesticide applicators.
The goal of any other worker safety risk mitigation projects should be enhanced protection of
workers that are occupationally exposed to pesticides.
2. REGION-SPECIFIC PESTICIDE PRIORITY: PROMOTE STATE AND TRIBAL
PESTICIDE PROGRAM COORDINATION AND COMMUNICATION
A. Description
It is now a goal of the Tribal Pesticide Program Council (TPPC) to encourage tribes, where appropriate
and feasible, to increase their communications and coordination with state pesticide programs as a
resource for tribes to build capacity for their own pesticide programs. Increased communication and
coordination between states and tribes, which respect tribal sovereignty and jurisdiction, can improve
tribal access to programmatic and technical expertise, support and training. Some states have also
expressed an interest in this cooperation as a way to increase assurance of adequate pesticide program
protection in Indian country within or contiguous to their borders and resources.
Examples of areas where state pesticide programs may be able to offer low cost support to tribal
pesticide programs (or vice-versa) include: offering a few seats to tribal pesticide program staffer
managers when training is conducted for state personnel; allowing tribal inspectors to accompany state
inspectors on inspections for training purposes; offering tribes access to or use of state tools, templates,
checklists or databases; sharing information on tips and complaints, violations or incidents that may be
relevant to Indian country; having states routinely inform tribes when they issue a FIFRA section 24(c)
or request a FIFRA section 18 from the EPA; sharing pesticide monitoring data; establishing state
technical and program expert contacts for tribal pesticide personnel; and offering tribes access to state
laboratories.
The EPA regional offices can help support the TPPC goal and facilitate increased communication and
coordination between tribal and state pesticide programs by acting as an intermediary and catalyst,
where appropriate and feasible. For example, regional offices may be able to encourage or help establish
state and tribal agreements of support. In some cases it may be appropriate to include specific activities
and goals in support of this priority in the state and tribal FIFRA Cooperative Agreements and
Workplans. All approaches must support and respect tribal sovereignty.
Efforts to build tribal pesticide program capacity through this approach supports Goal 4 of the agency's
Strategic Plan by protecting human health and the environment in Indian country from pesticide risk.
This priority can also support the agency's tribal and environmental justice goals. This approach is also
consistent with Principle #6 of the agency's 1984 Indian Policy, which encourages communication and
cooperation between tribal, state and local governments.
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B. Regional Activities
Regional offices emphasizing this area must conduct at least one region-specific project/initiative to help
foster state and tribal coordination and communication.
3. REGION-SPECIFIC PESTICIDE PRIORITY: BED BUG OUTREACH/ASSISTANCE
A. Description
Over the last several years, bed bug complaints and infestations have increased markedly in some areas
of the country, and the spread of bed bug infestations are predicted to increase. People seeking effective,
cheap and rapid solutions have in some cases resorted to the use of unregistered pesticide products or
misuse of registered products.
The EPA's efforts to address bed bugs have focused on: 1) encouraging use of pesticides effective
against bed bugs that do not pose unreasonable risks to people or the environment; 2) promoting the use
of integrated pest management for bed bug control; 3) discouraging the use of unregistered pesticides or
the overuse of registered pesticides as measures to control bed bugs, 4) providing information to the
public on bed bug infestations, and 5) collaborating with other agencies and stakeholders to share
information on bed bug control.
Efforts to provide bed bug outreach and assistance supports the Goal 4 of the agency's Strategic Plan by
protecting human health from pesticide risk. This priority can also support the agency's environmental
justice goals because economically-challenged segments of the population may have more trouble
controlling an infestation due to the relatively high cost of effective treatment, the presence of multi-
family housing and limited access to information.
B. Regional Activities
Regional offices emphasizing this area must conduct at least one region-specific project/initiative
contributing to education about prevention of, or response to, bed bug infestation, or providing
technical assistance to states, tribes, pest management professionals, local bed bug programs,
environmental justice advocates, the general public, or other stakeholders.
Assist OPP in the development and dissemination of information related to bed bugs and their
control.
In order to assure efficient use of resources, regional offices should take steps to avoid duplication of
efforts in developing materials, trainings and meetings by consulting with the Bed Bug
Clearinghouse on the EPA website (http://www.epa.gov/bedbugs/bedbug-clearinghouse.html) and
by communicating with OPP and other regional offices (such as through OPP/regional Bedbug
Communications Workgroup). Regional offices should contribute relevant information to the Bed
Bug Clearinghouse and should encourage states and local agencies to consult and contribute to the
clearinghouse as well.
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Where feasible, regional offices should also consider:
Establishing relationships with other federal, state, tribal and local agencies within the region to
assist them where needed in their combined bed bug infestation responses/activities.
Assisting states in detecting and stopping distribution of unregistered pesticides intended for use
against bed bugs.
Providing financial assistance to states for bed bug research, outreach and education.
4. REGION-SPECIFIC PESTICIDE PRIORITY: ENDANGERED SPECIES PROTECTION
Under the Endangered Species Act (ESA), the EPA strives to protect endangered/threatened plants and
animals (listed species) and the habitats upon which they depend. Through risk assessment and
mitigation, OPP's goal under the Endangered Species Protection Program (ESPP) is to limit potential
effects from pesticide use to listed species, while at the same time not placing undue burden on
agriculture or other pesticide users. Further information on the ESPP can be found at
http://www.epa.gov/oppfeadl/endanger/.
Regional offices should focus on acting as liaison between OPP headquarters office and states/tribes and
pesticide users on potential impacts of pesticide use on threatened and endangered species. Regional
offices should also continue outreach and education on the ESPP with the goal of increasing state, tribal,
territory and public knowledge of the program. Where Bulletins are being developed, regional offices
play a critical role in facilitating input on proposed limitations and placing additional emphasis on
educating pesticide inspectors.
Activities to support the Endangered Species Protection Program supports Goal 4 of the agency's
Strategic Plan by protecting the environment from pesticide risk.
A. Regional Activities
Regional offices emphasizing this area must conduct at least one region-specific project/initiative
contributing to implementation of the National Pesticide Program Endangered Species Program and
increased co-regulator and public knowledge about the ESPP.
Regional offices should also assist OPP in disseminating and obtaining review and comment on
ESPP-related information such as draft pesticide risk assessments, draft Biological Opinions,
measures recommended by the Services through Biological Opinions and draft Bulletins, including
crop data, pesticide use data and the feasibility of proposed mitigation measures.
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5. REGION-SPECIFIC PESTICIDE PRIORITY: POLLINATOR PROTECTION
OUTREACH
A. Description
Through risk assessment, mitigation, education and outreach, the agency's goal under the Pollinator
Protection Program is to ensure pollinators are protected from adverse effects of pesticide exposure.
Coordination between headquarters, regional offices and state and tribal pesticide agencies, as well as
industry, commodity groups, growers, applicators and stakeholders representing pollinators, will help us
meet our pollinator protection objectives. Pollinator Protection Outreach supports Goal 4 of the agency's
Strategic Plan by protecting the environment from pesticide risk.
B. Regional Activities
If selected as a regional priority, conduct at least one region-specific project/initiative contributing to
the education or collaboration of stakeholders (such as growers, applicators, commodity groups,
pesticide manufactures, or crop advisors) on pesticide and pest control practices that can help protect
bees and other pollinators (e.g., IPM or Best Management Practices (BMPs)). Outreach should also
include information on pollinator incident reporting mechanisms.
Projects can also include gathering incident data involving pollinators for submission to OPP (events
where pesticide application is known or suspected in causing the death or other adverse toxicological
effects on pollinators or pollinator colonies).
Projects may also include short-term pollinator protection research projects which are conducted
with or sponsored by ORD, and which have been reviewed and approved by the Office of Pesticide
Programs. This review and approval is to assure the usefulness of the research project in the context
of other efforts, as well as the study goals and methodology are acceptable for regulatory purposes.
6. REGION-SPECIFIC PESTICIDE PRIORITY: SPRAY DRIFT INCIDENT DATA
A. Description
In 2013, the EPA plans to initiate the voluntary Drift Reduction Technology (DRT) Program to
encourage the identification and use of pesticide spray application technologies verified to substantially
reduce spray drift. Such technologies may include spray nozzles, shrouds and shields and drift-reducing
adjuvant chemicals used for aerial or groundboom applications to row and field crops. OPP will
encourage manufacturers to test their technologies to verify and quantify drift reduction potential, and
OPP will encourage registrants to label their agricultural pesticides for application with these
technologies. As a result of this program, OPP expects to see their increased adoption of drift reduction
technologies on pesticide labels and by pesticide applicators. Agricultural spray drift incident data,
collected over time, can help the EPA gauge the effectiveness of this program. Regional offices are
ideally positioned to work with states and tribes to gather these data for analysis by OPP. This pesticide
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program-specific priority supports Goal 4 of the agency's Strategic Plan by protecting the environment
from pesticide risk.
B. Regional Activities
If selected as a regional priority, regional offices should work with their states and tribes to gather
agricultural spray draft incident data from the past 2-3 years (2011-2013) to form an incident baseline
and then gather data for 2014. The key parameter is number of incidents investigated by the states,
tribes, or EPA related to spray drift of agricultural pesticides. More detailed information includes: state
or tribe where the incident occurred, identifying if the incident is the result of aerial or ground
application, if DRT equipment was used and if so identification, pesticide product used, target site (e.g.,
row/field crop or orchard), drift site (e.g., home, school, crop, wetland), effect of concern observed, and
enforcement action (e.g., no action, notice of warning, civil penalty, criminal penalty). Regional offices
should consult with OPP for further guidance on incident data for collection. These data will help inform
the EPA and states/tribes about the success of the new program and ideas from making further
improvements to reduce spray drift incidents.
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VII. PROGRAM-SPECIFIC GUIDANCE FOR THE OFFICE OF POLLUTION
PREVENTION AND TOXICS
COMMUNITY ACTION FOR A RENEWED ENVIRONMENT (CARE)
A. 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. 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.
More information regarding the CARE Program can be found at http://www.epa.gov/care/.
B. Regional Activities
Regional offices should continue to provide multi-media support needed to ensure the success of their
CARE cooperative agreements.
C. Measure
(ACS Code: CAREl) Number of Community Action for Renewed Environment (CARE) cooperative
agreement projects managed in order to obtain reductions in toxics at the local level.
The ACS CAREl measure is a non-commitment measure.
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.
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FINAL FY 2014 OCSPP NPM GUIDANCE
VII. APPENDIX A: NPM GUIDANCE MEASURES
4/1
IPM2
Measure Text
Number of activities conducted, consistent with the EPA
"Strategic and Implementation Plan for School Integrated
Pest Management," to provide outreach, education, and/or
assistance to public schools at the kindergarten through high
school levels to adopt verifiable and sustainable IPM
practices.
Non- State National
Commitment Performance Planning Target
Indicator Measure Target (FY 2014
(Y/N) (Y/N) Pres. Bud)
Y
N
Activities defined as substantial increments of work with one or more internal or external stakeholder(s) or development of program capacity such as databases or
educational resources to advance IPM in schools. In order to keep a wide range of activities somewhat comparable, each reported activity should generally include 1)
preparation, 2) substantive participation, and 3) follow-up actions as needed.
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Goal/
Objective
ACS
Code
Measure Text
Non- State National
Commitment Performance Planning Target
Indicator Measure Target (FY 2014
(Y/N) (Y/N) Pres. Bud)
4/1
4/1
4/1
CORE
RSP2
13A
Percent of overall required pesticide program cooperative
agreement activities that are included in grantee workplans
and completed consistent with the pesticide program portion
of the FIFRA Grant Guidance.
Number of region-specific projects or initiatives
contributing to the implementation and enhancement of the
Region-Specific Pesticide Priority areas.
Annual percentage of viable lead-based paint abatement
certification applications that require less than 20 days of
EPA regional office effort to process (Direct
Implementation).
N
N
N
N
N
N
100%3
2 per
Region
95
Percent of pesticide program core activities completed by grantee as compared to the total required by pesticide program portion of the FIFRA grant guidance.
Where core activities are not completed, they can be removed from the total required provided a reasonable rationale for not completing the core activity is documented
(e.g., unexpected loss of staff or unplanned crises during the project period). Since end-of-year reports for these cooperative agreements are not due to OPP from the
regions until February 28, data for this ACS measure will not be available at the end of the fiscal year for reporting into ACS. When regions report their ACS measures at
the end of the fiscal year, they may indicate in the comment field for this measure that this data will not be available until February/March and will be reported at that
time.
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FINAL FY 2014 OCSPP NPM GUIDANCE
Goal/
Objective
ACS
Code
Measure Text
Non- State National
Commitment Performance Planning Target
Indicator Measure Target (FY 2014
(Y/N) (Y/N) Pres. Bud)
4/1
4/1
4/1
4/1
4/1
4/2
4/2
4/2
4/2
3/4
13B
14
RRP2
TR-1
TSCA1
262
263
264
297
CARE1
Annual percentage of viable lead-based paint abatement
certification applications that require less than grantee state-
established timeframes to process.
Number of lead abatements performed by certified
abatement contractors occurring in the region.
Number of active lead-based paint renovation, repair and
painting certification training providers accredited by the
regional office.
Number of tribal partnerships or projects addressing lead-
based paint hazards and exposure reduction in the region.
Number of activities conducted to reduce or prevent
exposure to chemicals of concern, with a focus on PCBs.
Gallons of water reduced through pollution prevention.
Business, institutional and government costs reduced
through pollution prevention.
Pounds of hazardous material reduced through pollution
prevention.
Metric tons of carbon dioxide equivalent (MTCO2e)
reduced or offset through pollution prevention.
Number of Community Action for Renewed Environment
(CARE) cooperative agreement projects managed in order
to obtain reductions in toxics at the local level.
N
Y
Y
Y
Y
N
N
N
N
Y
Y
N
N
N
N
N
N
N
N
N
95
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FINAL FY 2014 OCSPP NPM GUIDANCE
VIII. APPENDIX B: EXPLANATION OF CHANGES BETWEEN FY 2013 AND FY 2014
Change from FY 2013 Guidance Document
National Areas
of Focus
Modification: Cross-Regional Priorities are now
called National Focus Areas.
Addition: A new National Focus Area called
"Coordinating with State/Tribal Pesticide Agencies
and Regional Water Programs to Obtain Pesticide
Water Quality Monitoring Data."
Modification: "Region-Specific Pesticide
Priorities" is a National Focus Area and the details
of each of the priority areas are now located in the
"Program-Specific Guidances for the Pesticides
Program" section.
Deletion: The FY 2013 OPP Region-Specific
Priority Area pick-list item, "Support of the
Agricultural Sector."
Reason for Change
This change is consistent with the new agency NPM
format and terminology.
The activities described under this priority were
described as routine work in the FY 2013 OCSPP
NPM Guidance, and are therefore not new or
additional regional workload in FY 2014. However,
we felt that the importance of this work warranted
highlighting this effort as a National Focus Area in
FY 2014. The work described under this priority will
help the Pesticide Program obtain access to existing
water monitoring data which is not already available
in STORET or otherwise publicly available so that
this data can be considered in pesticide risk
assessments and appropriate risk mitigation can be
identified if needed.
This change is consistent with the new agency NPM
format and terminology.
The expectation is that the work formerly addressed
by this priority will be covered by the new FY 14
Region-Specific Pesticide Priorities of "Pollinator
Protection Outreach" and "Spray Drift Incident Data."
Affected
Sections
Section II
Section II.:
Section II.4
and Section
IV
Section
IV.5 and
Section
IV.6
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Change from FY 2013 Guidance Document
Deletion: Did not include the Chemical Risk
Review and Reduction (CRRR) Program as one of
OPPT's National Areas of Focus or in the Program-
Specific Guidance section.
Modification: Under Pollution Prevention Program,
using a new structural approach that breaks
priorities into two categories: "Foster the
Development of P2 Innovations" and "Promote the
Use, Adoption and Market Penetration of P2
Innovations."
Addition: Accelerated time frame for obligating
100% of P2 and Lead STAG funds from end of FY
to June 30th, pursuant to decision made at October,
2012 OCSPP RDD meeting.
Deletion: The FY 2013 OPP Region-Specific
Priority pick-list item called, "Protection of Water
Resources from Pesticide Exposure (including
support for implementation of the NPDES Pesticide
Permits)."
Reason for Change
Prior to the restructuring the NPM Guidance for FY
2014, OPPT's approach was to provide a description
of all of its programs, not just those associated with
regional offices' resources. The new streamlined
structure for FY 2014 comprised of National Areas of
Focus and Program-Specific Guidance for regional
offices does not lend itself to that approach, so instead
the CRRR program (which has no regional offices
resources) is described only in the OCSPP overview.
Affected
Sections
This structural approach is in response to overall
input to make the NPM Guidance more useful and
functionally valuable as guidance on priorities to the
Regions and reflects evolving thinking about how to
organize and present publically the P2 program.
Accelerated obligation schedule will facilitate
redirection of unobligated funds to ensure obligation
by end of FY.
The expectation is the work specifically targeted by
this priority is better represented as part of the work
done by regions to support grantees in the National
Focus Area called "Strengthening State/Tribal
Partnerships Through Continued Effective
Management Grants/Cooperative Agreements."
Additionally, by FY 2014, we also do not anticipate
the need for continued emphasis to support for
implementation of the NPM Pesticide permits as we
have done in FY 2012 and 2013.
Section I
Section
III. 3
Section
Ill.land
Section
III. 3
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FINAL FY 2014 OCSPP NPM GUIDANCE
Change from FY 2013 Guidance Document
Program-
Specific
Guidance
Addition: Under the Region-Specific Pesticide
Priority, regions will be given an option of doing a
project to support "Pollinator Protection Outreach."
Addition: Under the Region-Specific Pesticide
Priority, regions will be given an option of doing a
project to support "Spray Drift Incident Data."
Modification: The Region-Specific Pesticide
Priority list "Expansion of Pesticide Protection in
Indian Country" has been modified to focus on
activities that can facilitate improved
communication and cooperation between the states
and tribes. Under the Region-Specific Pesticide
Priorities, regions will be given an option of doing a
project to "Promote State and Tribal Coordination
and Communication."
Modification: OCSPP is the co-lead for the CARE
program in FY2014.
Reason for Change
This program area was proposed because there is a
significant investment and priority of EPA
headquarters' resources in this environmental concern
and a clear potential for regional office involvement
and support. Similarly, regional involvement in this
area would be consistent with state and tribal
priorities planned for the FY14/15-17 FIFRA
Cooperative Agreement Grant Guidance.
Affected
Sections
This program area is proposed because there is a
significant investment and priority of EPA
headquarters' resources in this human health and
environmental concern and a clear potential for
regional office involvement and support. Similarly,
regional involvement in this area would be consistent
with state and tribal priorities planned for the
FY14/15-17 FIFRA Cooperative Agreement Grant
Guidance.
It is now a priority for Tribal Pesticide Program
Council (TPPC) to help tribes build capacity and
leverage their programs by improving communication
and coordination with states. Regions are ideally
situated to support this TPPC goal by facilitating a
cooperative and supportive state and tribal
relationship that still respects tribal sovereignty and
jurisdiction.
The change is due to the CARE executive
committee's decision to have the CARE lead and co-
lead change every two years.
Section IV
Section
IV.6
Section
IV.2
Section V
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FINAL FY 2014 OCSPP NPM GUIDANCE
Change from FY 2013 Guidance Document
Annual
Commitment
Measures
Deletion: We are proposing the deletion of the ACS
measures associated with the old "Region-Specific
Pesticide Priority" area, Expansion of Pesticide
Protection in Indian Country, which were ACS
codes: TR-2 (Number of tribes covered under tribal
pesticide program or enforcement agreements), TR-
3 (Number of people in Indian country covered
under tribal pesticide program or enforcement
agreements) and TR-4 (Number of acres in Indian
country covered under tribal pesticide program or
enforcement agreements).
Modification: ACS Code 14
Original Language: Number of abatement activities
performed by certified abatement workers occurring
in the region.
New Measure Language: Number of lead
abatements performed by certified abatement
contractors occurring in the region.
Reason for Change
These ACS measures reflected progress on our
previous NPM tribal goal of expanding coverage of
the pesticide program in Indian country. They do not
reflect progress on our revised tribal pesticide NPM
goal of "Promoting State and Tribal Coordination
and Communication." However, it is important to
note that expanding pesticide program coverage in
Indian country remains a goal of the Pesticide
Program Tribal Strategic Plan, and the program will
track progress of this goal using these former ACS
measures through other means for the next few
years.
Affected
Sections
The language modification was in response to the
internal measurement review process with the
regions. This language will ensure that regions are
consistently tracking work.
Section
III.l and
Appendix
A
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FINAL FY 2014 OCSPP NPM GUIDANCE
IX. APPENDIX C: KEY PROGRAM CONTACTS
Contact Name
Jennifer Vernon
Subject Area
OCSPP Planning and Accountability Lead
NPM Guidance Development
Phone
202-564-6573
Email
vernon.iennifer@epa.gov
Daniel Helfgott
Office of Pesticides Programs
Field and External Affairs Division
703-308-8054
helfgott.daniel@epa.gov
Mike Burns
Office of Pollution Prevention and Toxics
Environmental Assistance Division
202-564-8273
burns.mike@epa.gov
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X. APPENDIX D: FY 2014 EXTERNAL COMMENTS AND RESPONSE TO COMMENTS SUMMARY
TEMPLATE
Comment from State, Tribe, or
Other Stakeholder
Commenter(s)
Location in NPM Response
Draft
Guidance
Action Taken in Final
Guidance
ISSUE AREANATIONAL AREA OF FOCUS: STRENGTHENING STATE/TRIBAL PARTNERSHIPS THROUGH CONTINUED
EFFECTIVE MANAGEMENT OF GRANTS/ COOPERATIVE AGREEMENTS
Consider utilizing grants and
cooperative agreements to enlist
the assistance of state and local
government environmental
laboratories to accomplish
OCSSP's goals. APHL and its
member laboratories work closely
with EPA through a cooperative
agreement with the Office of
Water and are familiar with the
operations of EPA. OCSSP can
develop closer relationships with
states through a working
arrangement with APHL and its
member, government laboratories.
Assoc. of Public
Health
Laboratories
Page 8 et
seq.
We will look into this suggestion should
additional funding become available.
No change.
ISSUE AREANATIONAL AREA OF FOCUS: COORDINATING WITH STATE/TRIBAL PESTICIDE AGENCIES AND
REGIONAL WATER PROGRAMS TO OBTAIN PESTICIDE WATER QUALITY MONITORING DATA
Consider utilizing state and local
government environmental
laboratories to assist in obtaining
and evaluating pesticide water
quality data. OCSSP can
significantly advance its goal of
Assoc. of Public
Health
Laboratories
Page 10 et
seq.
We agree that state and local
government environmental laboratories
can be excellent resources in obtaining
and evaluating water quality data related
to pesticides and we strongly encourage
these laboratories to share with EPA any
No change.
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FINAL FY 2014 OCSPP NPM GUIDANCE
coordinating with state agencies
for pesticide water quality
monitoring through relationships
with state and local government
environmental laboratories.
pesticide water quality data or evaluation
they have not already submitted to EPA.
The new guidance for our pesticide
cooperative agreements with states and
tribes will also encourage state and tribal
pesticide agencies to seek this
information if it already exists. Our FY
14 NPM gets at this point by asking the
regional pesticide offices to work with
the regional water offices to obtain this
data if it already exists. However, due to
resource limitations, we do not believe
we can ask state or local environmental
laboratories to obtain new monitoring
data or conduct new evaluations they are
not already doing as part of an existing
program.
ISSUE AREA NATIONAL AREA OF FOCUS: POLLUTION PREVENTION PROGRAM
Page 20. Recommend more
clearly incorporating sustainability
and product life cycle terms and
concepts into the description.
Page 21, recommend that
partnerships with other federal and
state agencies also be suggested in
this partnership initiative, for
Division of Solid
Waste
Management
(DSWM)
Tennessee
Department of
Environment &
Conservation
(TDEC)
Division of Solid
Waste
Management
(DSWM)
Page 20
Page 21
We did not incorporate suggested edit
because the description paragraph
mirrors what is in the President's
Budget. While the guidance briefly
incorporates sustainability, the program
is planning to further emphasize
incorporating sustainability concepts in
the Agency's next strategic plan cycle
beginning in FY15.
The revised language clarifies the
additional parties involved with E3
partnership work.
No change.
Modified.
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FINAL FY 2014 OCSPP NPM GUIDANCE
example, partnering with the
Department of Agriculture.
Tennessee
Department of
Environment &
Conservation
(TDEC)
ISSUE AREA 2. REGION-SPECIFIC PESTICIDE PRIORITY: BED BUG OUTREACH/ASSISTANCE
Page 26, recommend adding
research and development. EPA
could either initiate and/or partner
to encourage research and
development into new methods,
products, and technologies. This
would apply not only to this issue
but other issues.
Division of Solid
Waste
Management
(DSWM)
Tennessee
Department of
Environment &
Conservation
(TDEC)
Page 26
We agree that encouraging research and
development for safe and effective
control of bedbugs is important, and
OPP does use various mechanisms to
accomplish this goal. However, we do
not believe that this is an effective
strategy in the context of this NPM
Guidance, which is intended to outline
the work the regions can do to support
national pesticide priorities. Instead, we
believe regional resources can most
effectively address bedbugs through the
education and assistance activities
described in the proposed FY 14 NPM
guidance.
No change.
ISSUE AREA GENERAL COMMENTS
ECOS supports many of the aims in
the OCSPP NPM guidance document
to prevent pollution and ensure the
safety of chemicals.
Teresa Marks
President,
ECOS
Page 6
II
OCSPP thanks ECOS for taking the time
to review the agency's NPM Guidance
documents and its support of OCSPP
programs.
No change.
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