UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 204SO
EPA-SAB-Letter-90-001
ctobetr 12, 1989
Honorable William K. Reilly ™c
Administrator*
U. S. Environmental Protection Agency
401 M Street, S. W.
Washington, D. C. 20460
Dear Mr. Reilly:
During FI89 the Science Advisory Board (SAB) and the Office
of Drinking Water (ODW) have participated In an innovative
approach In providing scientific and engineering advice to the
Agency. Vie are writing to Inform you of the procedure and to
describe briefly its generally successful results to date.'
Often in the past the SAB has remarked on the need to be
involved with the analysis of the scientific case early In the
development of a regulatory position by the Agency. The goal is
to assist the Agency in establishing a firm technical
foundation upon which to construct its risk management policy.
The more complex the technical issue, the more important it Is
to build that solid foundation early, a process which Includes
identifying critical research activities that should be
conducted In the near- to mid-term.
The question of appropriate methods for disinfecting
drinking water was chosen as an example of a complex topic In
which early consultation with the SAB could prove to be
particularly valuable. Specifically, the Agency Is considering
disinfection processes as alternatives to the traditional
chlorlnation process that has been used in this country for so
long. Before proposing specific regulations In this area, the
Agency must sort through a myriad of scientific and engineering
Issues such as the efficacy of the different 'disinfection
processes, the engineering aspects of the various approaches,
the detection and identification of disinfection byproducts, and
the toxicology of those substances.
In a series of public meetings (Oct. 13-1^, 1988; Dec, 1-2,
1988; and April 6-7, 1989), the Drinking Water Subcommittee
(DWS) of the SAB's Environmental Health Committee (EHC) and ODĄ
met to examine these complex technical questions. These
meetings were unique in that the Agency and the SAB have been
discussing —' in a generally collegia! manner — the scientific
basis for the regulatory approach, far In advance of a formal
SAB review of a technical document describing an established
Agency position, which has been the more traditional point of
input for the SAB.
-------
- 2 ~
In contrast to historical practice, the DWS communicated a
summary of these deliberations directly to ODW on June 30, 1989.
The DWS highlighted particular issues, identified research
gaps, and suggested alternative approaches to resolving
certain conceptual problems; e,g,, evaluating the toxlclty of
innumerable disinfection byproducts. That summary was not
reviewed by the EHC or the Executive Committee of the SAB;
therefore, it does not constitute a formal SAB report and is
not intended to prompt a formal response from the Agency.
The ODW is In the process of developing a fTstrawman regulation"
for disinfection and disinfection byproducts that will be
reviewed by the Subcommittee this fall and will result in a
^fortnal SAB report.
We are watching with Interest to determine whether this
experimental use of early and less formal, but still public,
Interaction with the program office has been of such benefit as
to recommend a similar procedure in other situations. In any
event, it is our intent, in keeping with comments you have made,
to continue exploring additional avenues by which the SAB can
be of assistance to the Agency.
Sincerely,
Rapooni'"~tJT~LQehrJ Chairman
Executive Committee
Science Advisory Board
Gary P. Carlson, Chairman
Drinking Water Subcommittee
Science Advisory Board
------- |