Draft Climate Change Adaptation Implementation Plan
The Office of Chemical Safety and Pollution Prevention (OCSPP)
                         June 2014


 To the extent this document mentions or discusses statutory or regulatory
authority, it does so for informational purposes only. This document does not
 substitute for those statutes or regulations, and readers should consult the
  statutes or regulations to learn what they require. Neither this document,
  nor any part of it, is itself a rule or a  regulation. Thus, it cannot change or
   impose legally binding requirements on EPA, States, the public, or the
   regulated community. Further, any expressed intention, suggestion or
 recommendation does not impose any legally binding requirements on  EPA,
   States, tribes, the public,  or the regulated community. Agency decision
makers remain free to exercise their discretion in choosing to implement the
   actions described in this Plan. Such implementation is contingent upon
            availability of resources and is subject to change.

The U.S. Environmental Protection Agency (EPA) is committed to identifying
and responding to the challenges that a changing climate poses to  human
health and the environment.

Scientific evidence demonstrates that the climate is changing at an
increasingly rapid rate, outside the range to which society has adapted in the
past. These changes can pose significant challenges to the EPA's ability to
fulfill its mission. The EPA must adapt to climate change if it is to continue
fulfilling its statutory, regulatory and  programmatic requirements. The
Agency  is therefore anticipating and planning for future changes  in climate
to ensure it continues to fulfill its mission of protecting human health and
the environment even as the climate  changes.

In February 2013, the EPA released its draft Climate Change Adaptation Plan
to the public for review and comment. The plan relies on peer-reviewed
scientific information and expert judgment to identify vulnerabilities to EPA's
mission and goals from climate change. The plan also presents 10 priority
actions that EPA will take to ensure that its programs, policies, rules, and
operations will remain effective under future climatic conditions. The priority
placed on mainstreaming climate adaptation within EPA complements efforts
to encourage and mainstream adaptation planning across the entire federal

Following  completion of the draft Climate Change Adaptation Plan,  each  EPA
National Environmental Program Office, all 10 Regional Offices, and several
National Support Offices developed a Climate Adaptation Implementation
Plan to provide more detail on how it will  carry out the work called  for in the
agency-wide plan. Each Implementation Plan articulates how the office will
integrate climate adaptation into  its planning and work in a manner
consistent and compatible with its goals and objectives.

Taken together, the Implementation Plans demonstrate how the  EPA will
attain the 10 agency-wide priorities presented in the Climate Change
Adaptation Plan. A central element of all of EPA's plans is to  build and
strengthen its adaptive capacity and work with its  partners to build capacity
in states,  tribes, and local communities. EPA will empower its staff and
partners by increasing their awareness of ways that climate change may
affect their ability to implement effective programs, and by providing them
with the necessary data, information, and tools to  integrate climate
adaptation into their work.

Each Program and Regional Office's Implementation Plan contains an initial
assessment of the implications of climate change for the organization's goals
and objectives. These "program vulnerability assessments" are living
documents that will be updated as needed  to account for new  knowledge,
data, and scientific evidence about the impacts of climate change on EPA's
mission. The  plan then identifies specific priority actions that the office will
take to begin addressing its vulnerabilities  and mainstreaming climate
change adaptation into its activities. Criteria for the selection of priorities are
discussed. An emphasis is placed on protecting the  most vulnerable people
and places, on supporting  the development of adaptive capacity in  the
tribes, and  on identifying  clear steps for ongoing collaboration with tribal

Because EPA's Programs and Regions and partners will be learning  by
experience as they mainstream climate adaptation planning into their
activities, it will be essential to evaluate their efforts in order to understand
how well different approaches work and how they can be improved. Each
Implementation Plan therefore includes a discussion of how the organization
will regularly  evaluate the effectiveness of  its adaptation efforts and make
adjustments where necessary.

The set of Implementation Plans are a sign of EPA's leadership and
commitment  to help build the nation's adaptive capacity that is so vital to
the goal of protecting  human health and  the environment. Working with its
partners, the Agency will  help promote a healthy and  prosperous nation that
is resilient to  a  changing climate.
                                      Bob Perciasepe
                                      Deputy Administrator

                                      September 2013

       Draft: Climate Change Adaptation Implementation Plan
   The Office of Chemical Safety and Pollution Prevention (OCSPP)
                              June 4, 2013


On October 5, 2009, the President signed Executive Order (EO) 13514 on
Federal Leadership in Environmental, Energy and Economic Performance1.
The EO established the Interagency Climate Change Adaptation Task Force
and tasked it with delivering a report within a year with recommendations on
policies and practices that Federal agencies can adopt that are compatible
with and  reinforce a  national climate change adaptation strategy. The Task
Force, co-chaired by the Council on Environmental Quality (CEQ), the
National Oceanic and Atmospheric Administration (NOAA), and the Office of
Science and Technology Policy (OSTP) delivered  the report to the President
on October 5, 20102. One of its recommendations calls for all Agencies to
develop a climate change adaptation plan. On March 4, 2011, the CEQ
issued guidance for Federal agencies to implement climate change
adaptation planning  in accordance with EO  13514. That guidance sets a
target for each  agency to develop a policy statement and an adaptation  plan.

On June 2, 2011, the EPA Administrator issued a policy statement on climate
change adaptation3.  The statement commits the Agency to develop an EPA
Climate Change Adaptation Plan to integrate climate adaptation into the
Agency's programs,  policies, rules, and operations. The statement also
directs all EPA program  and  regional offices to develop plans for
implementing the Agency-wide Climate Change Adaptation Plan. The Agency
1 EO 13514, October 5, 2009.
2 White House Council  on Environmental Quality, Progress Report on the Interagency
Climate Change Adaptation Task Force: Recommended Actions in Support of a National
Climate Change Adaptation Strategy (Washington, DC, October 5, 2010).
3 U.S. Environmental Protection Agency, Policy Statement on Climate-Change Adaptation,
June 2, 2011. http://epa.gov/climatechange/Downloads/impacts-adaptation/adaptation-

provided its draft plan it to OMB and CEQ during the summer of 2012. The
draft plan was publicly released on February 7, 20134.

Each program and regional office was asked to develop an implementation
plan, contributing to the Agency's adaptation plan that addresses certain key
elements in its implementation plans. The elements considered include:
programmatic vulnerabilities, priority actions,  role in the Agency's strategic
measures,  legal/enforcement, training/outreach,  partnerships with tribes,
impacts on vulnerable populations/locations, and  evaluation to inform the
organization's efforts to  integrate  climate adaptation into its activities.
Overview of OCSPP's Role in Implementing Agency Strategic Goals

Goal 4 of EPA's Strategic Plan is "Ensuring the Safety of Chemicals and
Preventing Pollution". OCSPP has the primary responsibility in its day-to-day
decisions to  ensure the safety of chemicals. OCSPP also is responsible for
managing the Agency's pollution prevention programs that are designed to
prevent pollution at the source, promote the use of greener substances, and
conserve natural resources.

Chemicals used to  make our products, build our homes, protect property and
crops, and support our way of life  can end up in the environment and  some
may accumulate in our bodies. A changing  climate can affect exposures to a
wide range of chemicals.  EPA's efforts to assess chemical safety, and to
implement chemical management decisions and pollution prevention
programs to minimize exposures could be impacted by changing
environmental conditions related to extreme weather events (e.g.,
increasing run off can  increase pollution in  nearby streams) or changing
chemical use patterns (e.g., changing pest pressure can affect the use of
agricultural chemicals).

The regulatory framework that OCSPP uses to ensure chemical safety  differs
for pesticides and other industrial  chemicals in commerce. Pesticides are
regulated under the Federal Fungicide, Insecticide and Rodenticide Act
(FIFRA) and  under the Federal Food,  Drug, and Cosmetic Act (FFDCA), which
4 EPA's Draft Climate Change Adaptation Plan, February 7, 2013.

                                 ~ 6 ~

are managed by the Office of Pesticide Programs (OPP) within OCSPP. Other
industrial chemicals in commerce are regulated under the Toxic Substances
Control Act (TSCA), which is managed  by the Office of Pollution Prevention
and Toxics (OPPT) within OCSPP. OPPT also administers the Pollution
Prevention Act through a series of programs that identify and  leverage
opportunities to prevent pollution.

Vulnerability Assessment

The effects on the environment resulting from climate change pose new
challenges to EPA as it strives to fulfill  its mission of protecting human health
and the environment.  Challenges resulting from a changing environment due
to climate change that may inhibit the  Agency's ability to fulfill its mission
are referred to as vulnerabilities. Vulnerabilities can be a physical change in
the environment causing increased exposure to chemicals or that may relate
to programmatic processes  or tools that may need  to  be adapted as a result
of a changing environment. This section discusses potential vulnerabilities to
the Agency's mission of ensuring chemical safety and  preventing pollution.
Overall, it is not likely the vulnerabilities discussed  below will impede
OCSPP's ability to carry out its core mission of ensuring chemical safety and
preventing pollution because many of its programmatic processes can be
readily adapted to address changing environmental conditions, including
those resulting from climate change.

Changes in chemical exposure can result from the effects on the
environment caused by a changing climate. For example, a changing climate
can alter pest pressure or the location  where crops are grown, which in  turn
may affect the rate, timing and/or frequency of chemical use.  Changing
environmental conditions may result in the introduction of new disease
vectors or invasive species that could increase the demand for evaluating
and making  decisions  regarding the safety of new chemicals or new uses of
existing products to address public health threats.

To make decisions on  the safety of chemicals,  EPA  relies on the best
available science and assessment tools and when quality monitoring data are
unavailable, it relies on models to  estimate exposures to chemicals. The
primary vulnerability OCSPP identified  for its chemicals management
programs is to ensure that the tools  and methodologies it uses remain
robust so that they reasonably reflect environmental changes,  including
those influenced by climate change.

OCSPP is examining the ways in which its models and tools may need
updating to account for changing environmental conditions and the potential
effects of climate change. OCSPP has begun to review the potential
implications of climate change for its current approaches to evaluating
pesticide/industrial chemicals exposures to  the environment and people
including children, agricultural workers, and other groups who may be
disproportionally exposed or affected.

The role of OPP is to make pesticide licensing and re-licensing decisions and
conduct additional program activities to ensure that pesticides are used in a
manner that is protective of human health and the environment. OPPT
assesses the potential safety of new and  existing industrial chemicals in
commerce on human health and the environment using the same or similar
models and tools as used to evaluate pesticide exposures. The
methodologies and tools used to assess pesticide risks have been peer
reviewed and are the state of the art used throughout the world. To ensure
that the underlying science  is sound in light of climate change, OCSPP is
evaluating its assessment tools to ensure that they address changes in
important environmental factors resulting from climate change.

To assist with the evaluation of potential  programmatic vulnerabilities, OPP
consulted with the FIFRA Scientific Advisory Panel (SAP)5 to seek advice on
areas within pesticide assessment processes that may be vulnerable to
changing climatic conditions. OPP asked the SAP to provide guidance on its
model review and preliminary conclusions, and on sources  of information
that may help fill knowledge gaps. The SAP concluded that climate change
would likely impact pest pressure, how and where pesticides are used, and
the quantity of pesticides used. The SAP agreed with OPP's preliminary
conclusion that since EPA reviews pesticide registrations  at least every 15
years using assessment methodologies that are conservative and protective
of human health and the environment, it is expected that the assessments,
and decisions based on them, will remain protective.

One area of vulnerability identified by the SAP was the use of increasingly
dated weather datasets in some models that estimate pesticide exposure.
The SAP  noted that the historical weather datasets might not fully reflect
5 The SAP is a Federal Advisory Committee established under the law to
provide advice on pesticide-related science issues.

recent changes in climate and current weather trends. OPPT has similar
concerns, especially in the assessment of chemicals that have the potential
for large releases to air and resulting exposures to the environment and
people,  including children. Some of EPA's exposure models that contain
climate-related variables may need updating as weather patterns,
temperatures, stream flow rates, air currents, precipitation rates, and other
climate variables continue to change. With input from the SAP, OCSPP has
begun to update its assessment approaches with the inclusion of current
weather data to ensure that its assessments reflect current environmental
conditions that could  include factors affected by climate change. In the
course of keeping its  modeling capabilities current, as other information and
resources become available,  OCSPP may need to consider incorporating
different assumptions or default environmental variables for physical-
chemical properties that may vary with a changing climate and
environmental conditions (pH, temperature, or flow rates).

Extreme weather events and impacts to energy production and use are
important considerations in OCSPP's Pollution Prevention Program.  Limited
availability of water and other natural resources are changing the way
manufacturers produce products, driving them to look for new ways to
reduce and reuse water and materials. Increased  demands on energy are
pushing  businesses to streamline production processes and  minimize waste.
The Pollution Prevention program did not identify additional vulnerabilities to
its programmatic capabilities that could result from changing climatic
conditions. The program's focus on water and energy conservation  supports
approaches and practices that businesses, communities, and state and local
governments will need to employ in order to respond to climate change.
Recognizing  the critical  role pollution prevention can play is an important
environmental consideration  within the context of climate change
adaptation. The Pollution  Prevention program did  not identify specific
vulnerabilities to its programmatic capabilities that could result from
changing climatic conditions although they may present new challenges.

There may be other changes in environmental conditions that could impact
chemical safety for which the Agency may need to consider.  Rising sea levels
and more frequent extreme weather events increase the vulnerability to
flooding and destruction of structures in low lying areas. Chemical storage
facilities may be located in low lying areas and could be at risk of increasing
potential for chemical releases into the environment as a result of major
weather events. Many farms are along major rivers, and storage facilities
and businesses supplying pesticides can be in close  proximity to the field

where pesticides are used. Similarly, industrial chemicals could be stored in
low lying areas near ports along the seaboard, rivers, and other waterways.
The Agency is not certain of the significance of this vulnerability; however,
further study to determine the location of chemical facilities that may be at
risk may be warranted.

              Summary of Program Vulnerabilities to Climate Change Impacts on Chemical Safety
  Climate Change Impact
Likelihood of
Focus of Associated EPA
 Increasing extreme
 Increasing heavy
  precipitation events
 Very likely     Protecting human health and
               ecosystems from chemical
 Likely         risks.
                                       Reduces pollution at sources
Likelihood EPA
 Program will
be Affected by
Example of Risks if Program were Impacted
               Assure that chemical exposure models continue to be protective
               in light of changes in the environment
               Changing in planting timing or location may affect the volume and
               timing of agricultural chemical  use which could impact the
               appropriate risk management decisions.
               Changing pest pressure in agriculture and public health may place
               additional demands on the new registration, special local need
               and emergency exemption processes.
               Chemical storage facilities may be located in low lying areas that
               may be increasing at risk due to sea level increases or an increase
               in severe weather events.
               Disruptions in energy or water supplies may increase demand for
               pollution prevention resources.

Priority Actions on Climate Change Adaptation

To determine which potential programmatic vulnerabilities may warrant
closer attention, OCSPP considered a number of criteria. Factors considered
included the ability to quickly mainstream climate change adaptation into
core processes, the likelihood for affecting core program goals, the scale of
the potential impact, the timing of the impact, and the severity of the
impact.  Vulnerabilities that can readily be incorporated into core processes
generally are addressed in OCSPP current approaches. These actions involve
little additional cost to the program. Some actions are currently underway,
while others may be addressed without additional resources.

OCSPP is positioned to address the effects of climate change and changing
environmental conditions on chemical safety and pollution prevention. The
principal challenge to the program is to ensure that the tools and models it
uses adequately reflect the changes in the environment that may affect
human health and the environment.

This section discusses climate change adaptation-related activities and
processes that OCSPP can readily mainstream  into its programs so that it
continues  to meet its protection goals.

Public Health Pesticide Registration
    The  spread or introduction of certain public  health  pests can be
     attributed, in part, to climate change.  OPP has and will continue to
     work aggressively with companies and researchers to identify safe pest
     control products and strategies to minimize adverse effects on public

Tools and Models
     Volatilization - In the past, the FIFRA SAP raised concerns that OPP's
     current risk assessment approach does not consider off-site movement
     due  to volatilization of pesticides. OPP now includes the potential for
     volatilization  in its screening level assessments and will keep climate
     change in mind as  it considers how to incorporate volatilization into its
     more refined assessments.

    Developing a spatial component to PRZM/EXAMS - The Pesticide Root
     Zone Model (PRZM) simulates chemical movement in unsaturated soil
     systems within and immediately below the plant root zone. PRZM is
                                  1 9
                                  -L L*

     often linked with the Exposure Analysis Modeling System (EXAMS),
     which simulates the processes that occur in a water body situated next
     to an agricultural field. The FIFRA SAP suggested that OPP consider the
     geographic changes in pesticide use that will likely occur as a result of
     climate change. OPP is currently developing a spatial component to
     PRZM/EXAMS that it expects to complete by 2014. This model
     development effort is expected to more fully account for regional
     differences in cropping, pesticide use, and environmental conditions.
     These changes will help ensure that pesticide environmental
     assessment methodology is resilient to changes in real-world
     conditions, including those caused by climate change.

     In the normal course of updating models and tools, OCSPP will
     consider new pathways and changes in chemical behavior resulting
     from a changing climate.

     OPPT also has developed a geospatial component for its web-based
     IGEMS (Internet Geographical Exposure Modeling System) model to
     advance its higher tier exposure modeling capability to assess
     exposure to chemicals, calculating environmental concentrations in air,
     soil, water, and ground water.  As resources are available, OCSPP
     could consider updating modeling capabilities to address changing
     assumptions or default variables for other physical-chemical properties
     that may vary with changing environmental conditions (pH,
     temperature, or flow rates).

Pollution Prevention
     OPPT's Economy, Energy, Environment (E3) framework helps
     manufacturers reduce energy usage and conserve natural resources.
     Helping businesses to employ energy conservation techniques and
     discover new ways to reduce and reuse water and materials better
     positions them to respond to resource challenges that may result from
     climate change.

Specific information and data that would support OCSPP's mainstreaming
efforts  include:

     Acquiring current weather data to incorporate into risk assessment
     tools. This effort is underway.

     Acquiring, as the budget allows, up-to-date chemical use information.

     Acquiring information to improve our understanding of the location of
     existing facilities and the effect extreme weather events might have on
     facilities in  low lying areas. Acquiring such information would be a part
     of an Agency-wide mapping effort lead by the Office of Research and
Agency-wide Strategic Measures on Climate Change Adaptation

The Agency's Strategic Plan 2011-2015 includes a strategic goal to
mainstream climate change adaptation into its programs. One specific
mechanism for achieving the mainstreaming goal is through the
development  of scientifically sound decision tools. The primary mechanism
by which the OCSPP will contribute to this goal is by ensuring that the tools
used to assess chemical risks continue to provide robust estimates of
potential risks in light of changing environmental conditions that may result
from climate change.

Legal and Enforcement Issues

OCSPP believes that any changes in the conditions for regulating, approving,
licensing or regulating chemicals can be accomplished in the current
regulatory or enforcement structure.

Training and Outreach

Existing training and outreach programs within OCSPP can be used to
communicate with, and educate the public about, any changes in the
permitted use of chemicals that may result from changing environmental
conditions. Internally, OCSPP will, as appropriate, encourage staff to
participate in  training developed  across the Agency regarding mainstreaming
of climate change adaptation into its programmatic work.
Partnerships with States and Tribes

OCSPP currently has existing mechanisms and strong partnerships with
states and tribes which can be utilized to seek input and communicate
programmatic activities related to climate change adaptation.

Vulnerable Populations and Places

Currently, OCSPP's assessment and decision making approaches take into
consideration the identification of populations that may be disproportionately
affected by chemical exposures. One area that may warrant further cross-
agency discussion and investigation is the impact of the potential exposures
to communities near chemical storage facilities in the event of a  significant
weather event.

Evaluation and Cross-Office Pilot Projects

Currently, OCSPP's key chemical assessment tools and science policies are
peer reviewed by the FIFRA SAP for pesticides and by the Agency's Science
Advisory Board  (SAB) for other industrial chemicals. OCSPP would use
independent peer review of any significant changes to assessment tools or