OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
FY 2023-2024 NATIONAL PROGRAM GUIDANCE
RESPONSE TO PUBLIC COMMENTS

EPA - 743S22001

Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance

On Page 30 of the draft OCSPP NPG for FY
2023-2024, there appears to be an
unintended hard return after the word
"with and before the words "limited-
English..." as shown below.

"...activities for individuals with

limited-English proficiency and
individuals with disabilities."

Nebraska
Department of
Agriculture

p. 30 of 33

Correction made.

Deleted hard return.

The NSC supports and agrees with the
purpose and ideals of the EPA P2
Program as outlined in the P2 program
description.

National
Steering
Committee
(NSC)for the
national
network of
state Small
Business
Ombudsman
(SBO) and
Small Business
Environmental

H. Program
Priority:
Pollution
Prevention (P2),
Page 23

Thank you for supporting
the goals and objective
outlined in the P2
program description.

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance



Assistance

Programs

(SBEAP)







The NSC encourages EPA to share with
regional SBEAPs any regional P2 case
studies. The SBEAPs are often involved in
P2 projects with small businesses and can
also serve as an additional platform for
communications as a means of
amplification of successes.

NSC

Enhance P2

Communications

and

Amplification,
Page 25

The P2 program
maintains a P2 case
studies web page which
houses detailed studies
on P2 best practices,
challenges for
implementing P2 and
lessons learned. These
case studies have
relevance to states,
tribes, businesses and
other NGOs. The case
studies may be accessed
here:

https://www.epa.gov/p2
/pollution-prevention-
case-studies.

The P2 program in the
process of updating this
page with new case
studies. EPA welcomes
the encouragement to
share P2 case studies
with regional Small
Business Environmental

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance







Assistance Program's
(SBEAPs).

Also, under EPA's P2
grant programs, grantees
are required to develop
and share at least one
case study detailing the
grant activities
undertaken. The P2
program supplies
guidance within the
appendices of its' grant
announcements noting
the elements to include
in a case study in order
to make the work
relevant to states, tribes,
businesses and other
NGOs. The program
further emphasizes in its'
announcements and has
an evaluating factor of
its' grant applications,
the need for eventual
grant recipients to
amplify P2 best practices
and widely share lessons



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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance







learned so that P2
information, tools are
readily available. This
type of outreach
contributes toward
increasing the
knowledge and benefits
of P2/source reduction.



The NSC would like to remind EPA that
the SBEAPs are designed as technical
assistance providers to small businesses
like those often found in EJ communities.
Many (though not all) SBEAPs include P2
activities as part of the technical
assistance they provide or may be
connected with a specific state P2
program. As such, the SBEAPs could be a
great resource as an opportunity for P2
technical assistance.

NSC

Nurture External
Capacity to
Achieve Results,
Page 25

EPA's P2 program
continually seeks ways to
expand its outreach to
interested partners and
stakeholders.

Made no changes to
NPG.

Suggest changing "fair treatment" to
"equitable treatment"

Environmental
Council of the
States (ECOS)

Page 3 (Section
1. Introduction
second bullet
point)

Thank you for your
comment.

Made no changes to
NPG.

EPA should explore the opportunity to
connect section F (TRI) to the EJ TRI work
currently being developed as well as
outreach to states to use those tools.

ECOS

Page 14 (Section

F)

EPA's TRI program
continually seeks ways to
expand outreach to
interested partners.

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance

OPPT's lead risk reduction program may
benefit from including an investigation
into other sources of lead exposure for
children and sharing this information as
part of outreach programs. For example,
King County in Washington state recently
identified high levels of lead in cookware.
There are likely other products that are
contributing to lead exposure.

ECOS

Page 19 (Third
bullet point
under strategy)

EPA agrees that
identifying and sharing
potential sources of lead
exposure is important in
the overall effort to
protect the public from
the harmful effects of
lead. EPA provides
publicly accessible
information on its
website on the potential
sources of lead
contamination and
exposures

(www.epa.gov/lead) and
plans to continue to
communicate this and
other important lead
health information
during EPA outreach
programs, training, and
activities.

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance

Is there a role for manufacturers in the
first bullet point under "Nurture External
Capacity to Achieve Results"? If so, it
would be good to add SCIL to the list.
Some businesses may be looking for
products but others may be looking for
chemicals.

ECOS

Page 25 (First

bullet under

"Nurture

External

Capacity to

Achieve

Results")

The section entitled,
"Nurture External
Capacity to Achieve
Results," contains a
second bullet which
builds off the first bullet
noted in the comment.
There is a role of the
Safer Chemical
Ingredients List within
the P2 program
framework. The second
bullet builds off the
language shared under
the first bullet.

Made changes to NPG
on p. 25.

Considering NEA #6 and the addition
support for the Biden Administration
priorities related to environmental justice
and climate change are very broad and
ambiguous. We recommend more
specificity around how to address these
topics, including what P2 opportunities
may benefit Indian Country and Alaskan
Native Villages and what P2 opportunities
or sectors EPA sees as a priority for
addressing climate change. It is currently
hard to know where to start with these
broad concepts.

ECOS

Page 24 (First

and

second

paragraph under
Section II — H —
Strategy)

EPA's P2 program is
currently developing two
new P2 grant programs
planned for 2023, which
are supported by
Infrastructure
Investment and Job Act
funds. These new grant
programs will provide
additional details on how
P2/source reduction can
address human health
and environmental

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance







concerns in
disadvantaged
communities. To provide
specificity to the
structure of these
anticipated grant
programs, the P2
program will conduct a
series of listening
sessions focused on
identifying EJ and climate
change issues that are
particularly relevant to
disadvantaged and
environmental justice
communities.



For the third sentence under
"Description", update to: "...reduce
expenditures, reduce waste, or
eliminate toxic chemical use that
immediately translates to..."

"Eliminate waste altogether" is a bit
repetitive, and it is important to include
and distinguish the difference between
toxic chemicals and wastes. Pollution
prevention focus on the full spectrum,
including upstream chemical use and

ECOS

Page 23 (First
paragraph under
Section II — H —
Description)

Thank you for your
comment.

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance

downstream waste generation.









Suggest clarifying the recommendation to
regional offices included in "Regional
offices should support states and tribes
who are developing or revising the scope
of their plans by: (e.g., expanding the
scope by (1) reducing chronic exposure of
pollinators to low levels of pesticides; (2)
encouraging agricultural practices that
reduce the overall environmental loading
of pesticides; and (3) reducing possible
pesticide contamination of wild blooming
host plants near treated cropland)
pollinator protection plans" or otherwise
clarifying the statement.

ECOS

Page 5 (Section II
B)

Agreed.

Updated NPG:

Regional offices should
support states and
tribes who are
developing or revising
the scope of their plans
to include: (1) reducing
chronic exposure of
pollinators to low levels
of pesticides; (2)
encouraging
agricultural practices
that reduce the overall
environmental loading
of pesticides; (3)
reducing possible
pesticide

contamination of wild
blooming host plants
near treated cropland;
(4) increasing pollinator
habitat; and (5)
expanding
outreach/education
regarding all of the
factors influencing
declines in pollinator

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance









health.

Consider adding "pollution prevention" to
list "for the purposes of addressing toxic
chemicals in their communities under
their own authorities, particularly for
community waste reduction and clean-up
actions."

ECOS

Page 16, (Section
II, F)

Thank you for the
suggestion. We will look
into this further.

Made no changes to
NPG.

Under activities, consider collaboration
with initiatives beyond EPA (such as NSF
Industry-University Cooperative Research
Centers) that are commercializing
solutions based in the principles of green
chemistry.

ECOS

Page 25 (Section
II, H)

Thank you for the
suggestion. We will look
into this further.

Made no changes to
NPG.

Additional funding is needed at the
Navajo Nation for the Navajo
Environmental Protection Agency
Pesticides Program to implement its
program. What formula will be used to
determine funding amounts? The mass of
the land to cover should be taken into
consideration.

Navajo Nation

Pesticides

Cooperative

Agreements

The current funding
formula does evaluate
tribal land mass.
However, OCSPP will
update the data and the
formula once additional
tribal funds are available.

Made no changes to
NPG.

In that context, we see an opportunity for
EPA to focus on "streamlining the
business processes (page 9 of the NPG
document)" and expand it for TSCA and
PFAS as well. That clarity on actions and
measurements on business processes
would provide guidance to the regional

ECOS

Office of Land
and Emergency
Management
(OLEM) NPG:
Page 9, Page 24-
25

EPA provides publicly

accessible information

on its website

https://www.epa.gov/as

sessing-and-managing-

chemicals-under-

tsca/risk-management-

Made no changes to
NPG.

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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance

offices, states, manufacturers, suppliers,
customers and other involved
stakeholders in those processes. For
example, there are more than 43,000
active chemicals in the market and EPA
processes approximately 500 chemicals
every year. However, the NPG document
mentions only PCB material regulated
under TSCA (Page 24-25). The need to
address the plan to streamline that
investigation, risk assessment, and
stakeholder communication process for
other active chemicals that pose high risk
is critical in this emerging contaminants
trend. The PFAS strategic roadmap states
that the regulatory scope under OLEM is
still seeking public comments. The linkage
and measurable actions for each of its
impacts is not clear in the NPG. This
generic approach might create confusion
to the regions and states and clarifying
the PFAS area under streamlining the
businesses might lead to the efforts
accomplishing our shared goals. In
summary, the national priorities of EPA to
be aligned and linked well with
measurements in the streamlining
business processes section in order to





and-polyfluoroalkyl-
substances-pfas



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Comment

Commenter(s)

Location in Draft
Guidance

National Program
Offices Response

Action Taken in Final
Guidance

accelerate environmental protection at
national, regional and state levels.









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