About Island Press Island Press is the only nonprofit organization in the United States whose principal purpose is the publication of books on environmental issues and natural resource management We provide solutions-oriented information to professionals, public officials, business and community leaders, and concerned citizens who are shaping responses to environmental problems In 1994, Island Press celebrated its tenth anniversary as the leading provider of timely and practical books that take a multidisciplinary approach to critical environmental concerns Our growing list of titles reflects our commitment to bringing the best of an expanding body of literature to the environmental community throughout North America and the world Support for Island Press is provided by The Geraldine R Dodge Foundation, The Energy Foundation, The Ford Foundation, The George Gund Foundation, William and Flora Hewlett Foundation, The James Irvine Foundation,The John D and Catherine T MacArthur Foundation, The Andrew W Mellon Foundation, The Pew Charitable Trusts, The Rockefeller Brothers Fund, The Tides Foundation, Turner Foundation, Inc., The Rockefeller Philanthropic Collaborative, Inc., and individual donors About the Pollution Prevention Education and Research Center The Pollution Prevention Education and Research Center (PPERC) addresses a broad range of issues associated with industrial production processes and the use of hazardous materials The Center’s mission is to conserve resources and reduce or eliminate the use of toxic substances through an interdisciplinary program of education, research, and outreach grounded in a philosophy of prevention rather than control Through the collaborative efforts of its members, PPERC is shifting the focus from “end-of-pipe” pollution control techniques to a front-end, systems approach which analyzes technologies, cycles of production and consumption, industrial structures, and policy instruments to reduce toxics use and protect human and environmental health Reducing Toxics Reducing Toxics A NEW APPROACH TO POLICY AND INDUSTRIAL DECISIONMAKING Edited by Robert Gottlieb Pollution Prevention Education and Research Center University of California, Los Angeles Washington, D.C • Covelo, California Copyright © 1995 by Island Press All rights reserved under International and Pan-American Copyright conventions No part of this book may be reproduced in any form or by any means without permission in writing from the publisher: Island Press, 1718 Connecticut Avenue, N.W., Suite 300,Washington, DC 20009 ISLAND PRESS is a trademark of The Center for Resource Economics Library of Congress Cataloging-in-Publication Data Reducing toxics: a new approach to policy and industrial decisionmaking / edited by Robert Gottlieb p cm Includes bibliographical references and index ISBN 1-55963-336-0 (pbk.) Pollution—Government policy Industrial management— Environmental aspects I Gottlieb, Robert, 1944– HC79.P55R43 1995 94-46257 658.4’08—dc20 CIP Printed on recycled, acid-free paper Manufactured in the United States of America 10 Contents Contributors Acknowledgments xi xiii Introduction Robert Gottlieb and Janice Mazurek PART I The Difficulty of Getting There:The Evolution of Policy The Pollution Control System:Themes and Frameworks Robert Gottlieb and Maureen Smith Managing Pollutions: Policy Conundrums Seeking Change:The Emergence of Pollution Prevention Conceptual Themes in Pollution Control Policy Tools in Pollution Control By Air,Water, and Land:The Media-Specific Approach to Toxics Policies Robert Gottlieb, Maureen Smith, and Julie Roque Introduction Air Water Land Media-Specific Administration Conclusion 10 13 17 20 25 26 33 40 44 49 Shifting to Prevention:The Limits of Current Policy Janice Mazurek, Robert Gottlieb, and Julie Roque Introduction TSCA’s Lost Opportunity Reconfiguring Single-Medium Regulation The Ambiguities of Pollution Prevention Legislation and Regulation Conclusion 58 59 67 73 85 vii viii Contents Disassociating Toxics Policies: Occupational Risk and Product Hazards John Froines, Robert Gottlieb, Maureen Smith, and Pamela Yates The Problem of the Workplace The Occupational Safety and Health Act The Role of Standards Acceptable Risk—Benzene Setting Priorities at OSHA—Problem Identification Enforcement—Are Pollution Prevention Strategies Available? Consumer Product Hazards 95 98 99 103 105 108 110 New Approaches to Toxics: Production Design, Right-toKnow, and Definition Debates Robert Gottlieb, Maureen Smith, Julie Roque, and Pamela Yates The Debate Over Terms and Strategy The Debates Toxics Use Reduction and Pollution Prevention Right-to-Know:The Role of Information Reducing Government’s Role: Comparing Risks, Creating Markets, and Emphasizing Technologies Locating Other Entry Points: State and Local Efforts The Terms: Linking Definitions to Policy Barriers to Prevention Pollution Prevention: An Environmental and Industrial Strategy 124 125 128 131 139 143 149 153 154 PART II Industry Settings: Opportunities and Limits for Pollution Prevention Greening or Greenwashing?:The Evolution of Industry Decisionmaking Robert Gottlieb, Maureen Smith, and Julie Roque Cautionary Precedents:The Tetraethyl Lead Case What Gets Decided: Organization and Management Issues Toxicology and Risk Assessment Environmental Audits and Life Cycle Analysis Green Marketing and Labeling Environmental Citizenship Decisionmaking and Production Outcomes 170 176 177 180 188 194 197 Contents The Chemical Industry: Structure and Function Maureen Smith and Robert Gottlieb Introduction Engine of Growth/Toxic Generator Establishing an Analytic Framework 209 210 220 The Chemical Industry: Process Changes and the Search for Cleaner Technologies David Allen Clean Technology and the Chemical Industry Clean Technology Options Process-Related Wastes and Emissions Control and Management Techniques: Costs and Trends The Opportunities for Cleaner Technologies Restructuring Processes Product Redesign and Raw Material Substitution for Waste Reduction Potential for Cleaner Technologies—Industry-Wide Perspectives Conclusion ix 233 235 237 246 248 262 263 269 273 Pollution Prevention for Emerging Industries:The Case of Electric Vehicles Julie Roque Separating Industrial Design and Environmental Management Electric Vehicles: “Clean” Products? Analyzing Industrial Processes: Using Lifecycle Analysis The Manufacture of Electric Vehicles Operating Costs Data Needs and Gaps Measuring Wastes and Hazards Plastic Components Electric Motors Electronics Batteries Conclusion 277 278 280 283 284 287 289 296 298 300 303 311 10 Substituting for Lead:The Radiator Repair Industry Tamira Cohen, Rania Sabty, and John Froines Resisting Change Industry Background 332 334 Index (CMA), 3, 74, 80, 134, 196, 245, 422 Chemical processing industries (CPI), 221, 222–223, 225 Chemical Specialty Manufacturer’s Association (CSMA), 118, 192, 365, 367 Chevron, 80, 251, 424 Children and lead exposure, 340 Chlorinated solvents, 301 Chlorinated Solvents Industry Alliance, 116 Chlorine, 38–40, 72–73, 218–220 Chlorofluorocarbons (CFCs), 61, 115– 116, 189, 362–364, 370, 377–379 Chloroform, 39, 218 Chromium, 69, 96 Cinci, Jeffrey, 193 Classical forms of regulation, 20–21, 30, 49–50 Clean Air Act Amendments (CAAA), 33, 58–59, 69–71, 175, 364 Clean Air Act (CAA) of 1963, 27 Clean Air Act (CAA) of 1970, 26–33, 72–73 Clean technology See Chemical industry; Electric vehicles (EVs); 3M Clean Water Act of 1972, 33–40 Clean Water Act reauthorization of 1994, 219 Clinton, Bill, 72, 84, 142, 154 Cluster industries, 83–84 CMA See Chemical Manufacturers Association (CMA) Coal-generated electricity, 284 Coalition for Environmentally Responsible Economies (CERES), 194–196 Coke oven emissions, 101 Colgate-Palmolive, 365 Command-and-control format for pollution control regulation, 15 Common Sense Initiative (CSI), 84–85 Communities at Risk:Your Right to Know About Toxics in San Diego, 136 Community activism in the toxics area, 423–424 See also Right-to-know proposals 435 Community Awareness and Emergency Response (CAER) program, 134, 196 Commute-A-Van program, 397 Comparative risk, 139–143, 177–180 Competitiveness Council, 81, 142 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, 43–44 Conceptual themes in pollution control, 17–20 Confidential business information (CBI) provisions of TSCA, 64–66, 74 Confidentiality and environmental audits, 182–183 Congress, U.S See also Federal role in pollution control/prevention; various legislative acts chemicals, lists of regulated, 135 Clean Air Act Amendments (CAAA), 69 consumer product hazards, 112 1960s pressures on, 10–11 prevention, pollution, 49, 422 single-medium basis for regulations, 72 waste sites, 44 workplace hazards, 96 Construction Safety Act of 1969, 98 Consumer Federation of America, 116 Consumer movement, 111–112 Consumer product hazards, 110–119, 374–377 Consumer Product Safety Act (CPSA), 112–113 Consumer Product Safety Commission (CPSC), 48, 110–118, 363, 377 Control system, pollution, 50 See also various subject areas chemical industry, 246–262 conceptual themes in, 17–20 evolution of policies within, 10–13 innovative, 46–47 integrated, 14–15 policy tools in, 20–22 prevention vs., 1–5, 13–17, 153–157 radiator repair industry, 344–348 436 Conventional pollutants, 19 Copper/brass radiators, 335, 351–353 Copper Development Association (CDA), 351 Copper mining, 136 Corporate environmentalism, 3, 80, 188– 194, 198 Cost-benefit analyses, 48–49 See also Economic costs of pollution control/prevention Council on Environmental Quality (CEQ), 45, 59, 81 Crisis in the Workplace (Ashford), 95 Crisis management focus of pollution policies, 11, 17–18 air pollution, 27–28 chemical regulation, 60–61 consumer product hazards, 110, 111 environmental audits, 180–181 environmental citizenship, 194 waste sites, 43 water pollution, 34 Criteria pollutants, 28 Cross-medium/pollution prevention action, 84 Custom fillers in aerosols industry, 365– 366, 370–371 Cutting Chemical Wastes, 183, 265 Decisionmaking, industrial, 3, 67 environmental audits, 180–183 environmental citizenship, 194–197 green marketing/labeling, 188–194 life cycle analysis, 183–187, 280–284, 288, 313–318 organization/management issues, 176– 177 production outcomes, 197–199 tetraethyl lead, 170–176 3M, 404–409 toxicology and risk assessment, 177–180 worker involvement in pollution prevention, 424–425 Definition debates over toxic policies, 124 Index linking terms to policy, 149–152 NRC/OTA/EPA reports, 125–128 prevention, pollution, 153–157 reducing or eliminating hazardous substances/waste, 128–131 right-to-know proposals, 131–139 risk assessment, 139–143 state/local efforts, 143–148 Deodorants, aerosol, 361–362 Diapers, 190 Dibromochloropropane (DBCP), 96, 97, 178 Dimethylaminopropionitrile (DMAPN), 97 Dioxin, 61, 69 Diseases associated with chemical exposure, 96–97 See also Health issues/ standards Disinfection byproducts, 38–40 Disjointed incrementalism, 17 Dow Chemical clean technology, 264 METH, 375 Pollution Prevention Act, 74 recycling, 148 solvents, chlorine-free, 380 tetraethyl lead, 177 TSCA, 60 voluntary approach by industry to accomplishing prevention goals, 80 Drinking water contamination, 38 Drucker, Peter, 393 Dry basis and mass of waste generation, 238 Dumps, open, 11, 40–44 Du Pont, 170–178, 212, 263–264, 363 Du Pont, Coleman, 175 Du Pont, Irenee, 172 Earth Day, 26 Economic costs of pollution control/prevention, aerosols industry, 372 anti-regulatory backlash, 48–49 automobile recycling, 317–318 chemical industry, 246–248, 266–269 Index Clean Air Act Amendments, 71 control system, pollution, 153–154 electric vehicles, 284–287 feasibility issue, 101–102 fugitive emissions, 251 full-cost accounting, 186–187 market-based incentive mechanisms, 7, 15–16, 401, 422 OSHA, 108 radiator repair industry, 349, 352 2% budgetary program for pollution prevention activities, EPA’s, 79–80 water pollution policies, 38, 39 Ecosystem related research, 47 Education programs for industry, 66, 155–156 Effluent limitations, point source, 35–36 Electric Power Research Institute (EPRI), 283 Electric vehicles (EVs), 311–312 aluminum production, 290–295 batteries, 303–311 clean technology?, 278–280 data needs/gaps, 287, 289 driving force behind, 318–319 electronics, 300–303 life cycle analysis, 313–316 motors, 298–299 operating costs, 284–287 plastic components, 296–298 Electronics, 300–303 Eli Lilly, 148 Emergency Planning Community Right-to-Know Act (EPCRA), 131 Emissions limitations, 28–31 Encyclopedia Britannica, 221–222 Energy, Department of, 240 Energy and plastic production, 297 Enforcement mechanisms, 84, 108–110 England, 390 Environmental assessments as part of development process, 277–278 Environmental audits, 180–183 Environmental certification programs (ECPs), 190–192 437 Environmental citizenship, 194–197 Environmental Defense Fund, 189, 424 Environmental Dividends: Cutting More Chemical Wastes, 183, 265 Environmental exposures from aerosols industry, 370–372 Environmental impacts by 3M, 394–396 Environmentalists, 74–75, 149, 362 Environmental Protection Agency, U.S (EPA), 12, 25, 421–422 acceptable risk, 104 aerosols industry, 376, 377, 378 ambiguities of legislation/regulation concerning pollution prevention, 73–85 CFCs, 363 chlorine, 219 Clean Water Act, 36 Comprehensive Environmental Response, Compensation, and Liability Act, 44 environmental audits, 181 hazardous waste, 41–42 life cycle analysis, 186 media-specific legislation, 44, 46–49 National Ambient Air Quality Standards, 28 pesticides, 112 prevention, pollution, 14, 59, 130–131 risk assessment, 139–143 Safe Drinking Water Act, 38–39 single-medium basis for regulations, 68–73 Source Reduction and Regulatory Review, 410 33/50 program for toxics reduction, 79, 80–83, 142, 396 TSCA, 61–67 waste minimization, 125–128 waste oil as dust suppressant, 117 worker participation in pollution prevention, 425 Environmental technologies, 143 See also Chemical industry; Electric vehicles (EVs); 3M EPA See Environmental Protection 438 Agency, U.S Ethylene glycol, 228 European Community (EC), 73, 192, 317, 367 European Organization for Economic Cooperation and Development (OCED), 62 Executive branch policy-making, 44–49 Exxon Valdez, 194 Feasibility issue and OSHA’s standards, 101–102 Federal role in pollution control/prevention See also Congress, U.S.; Environmental Protection Agency, U.S (EPA); specific legislative acts evolution of pollution control policies, 10–13 executive branch policy-making, 44–49 1960s, 27 occupational safety and health legislation, 97–98 reducing, 139–143 State Implementation Plans, 29 transportation control policies, 31, 32 Federal Trade Commission (FCC), 112, 189 Federal Water Pollution Control Act Amendments of 1972, 33–40 Federal Water Pollution Control Act (FWPCA) of 1948, 34 Federal Water Quality Administration, 45 Fetal toxicity, 340 Fifth Circuit Court of Appeals, 103, 114 Fisher, Linda, 67 Flammable propellants, 362, 379 Food, Drug, and Cosmetics Act of 1938, 110, 111 Food additives, 111 Food and Drug Act of 1906, 110 Food and Drug Administration (FDA), 111, 112, 116, 363 Ford, Gerald, 114 Formaldehyde content of products, 114 Fossil fuels, burning, 284 Freeman, Harry, 421 Index Front-end regulatory intervention, 63– 64 See also Prevention, pollution Frye, Arthur, 405 Fuel composition standards, 30 Fugitive emissions, 250, 251, 255, 370– 371 Full-cost accounting, 186–187 Gasoline, 30, 170–176 Gauley Bridge disaster, 96 General Accounting Office (GAO), 62 General Motors (GM), 171–175, 195 Generic classes of policy tools, 21–22 Generic hazard communication standards, OSHA’s, 107 Genesis program at 3M, 392 Germany, 236, 315 Gould, John, 146 Grants program for water pollution treatment programs, 37 Green marketing/labeling, 188–194 Greenpeace, 73 Green Seal, 190–191 Gregerson, John, 408 Groundwater, 35 Hamilton, Alice, 96, 110, 173, 177 HAP See Hazardous air pollutant (HAP) Hayes, Denis, 190 Hazardous air pollutant (HAP), 69, 70 Hazardous and Solid Waste Amendments (HSWA) to the RCRA, 58, 68, 75– 76, 124 Hazardous Substances Labeling Act of 1960, 110 Hazardous substances/waste, 41–43, 49–50 See also Chemical industry; Definition debates over toxic policies;Workplace hazards aerosols industry, 372 aluminum production, 290–295 batteries, 303–311 consumer products, 110–119 data on, 287, 289 electronics, 300–303 facilities for, 13 Post-It Notes, 406 Index screening/testing and phase-out provisions for, 58 single-medium basis for regulations, 68–69 Substance Research Centers, 77 33/50 program for, 79, 80–83, 142, 396 3M, 394–396, 411 TSCA, 59–67 Health Hazard Evaluations (HHEs), 106 Health issues/standards batteries, 307, 309 California public health officials, 32, 348 carcinogens at the workplace, 95–98 CBI claims, 65–66 consumer product hazards, 110–119 HAP, 70 OSHA, 98–107 radiator repair industry, 338–344 risk assessment, 63, 103–105, 139–143, 177–180 tetraethyl lead, 170–176 Heat exchangers in chemical industry, 259 Heme synthesis, 339 Henderson,Yandell, 174 HEPA (High Efficiency Particulate Accumulator) filters, 347 Heritage Foundation, 115 Holusha, John, 413 HSWA See Hazardous and Solid Waste Amendments (HSWA) to the RCRA Humphrey, Hubert, III, 189 Hydrocarbons (HC), 28 Hydrogen chloride, 69 Hypertension, 339 Improved Radiator Standards Association (IRSA), 352 Incineration, 41, 76, 246 Incremental nature of pollution policy, 17, 34 Indiana, 148 Indirect dischargers, 36 Indirect source and emissions standards, 29 Indoor air pollution, 117, 227 439 Industry settings, 167–169 See also Chemical industry; Decisionmaking, industrial; various subject areas INFORM, 183, 265–266 Information in policy elaboration, role of, 18–19 Ingested or inhaled lead, 338 Innovative pollution control technologies, 46–47 In Search of Excellence (Peters), 392 Inspections for chemical/physical hazards at the workplace, 105–106 Integrated Management Information System (IMIS), 106 Integrated pollution control, 14–15 Interagency Regulatory Liaison Group, 115 International Copper Research Association (ICRA), 351–352 International Joint Commission on the Great Lakes, 73 International Petrochemical Industry: Evolution and Location (Chapman), 221 Interstate Commerce Commission (ICC), 361 Interventionist mechanisms/reforms See Control system, pollution Jacobsen, Allen, 410 Japan, 236 Job Exposure Matrix (JEM), 106 Johnson, Lyndon, 98, 112 Johnson Wax company, 363 Jungle,The (Sinclair), 110 Kennecott Utah Copper, 136 Kepone, 60 Ketone, 297 Kettering, Charles, 171–172 Kidney damage, 339 Labeling requirements, 21, 118, 192 Lakes/rivers threatened by pollution, 11 Land disposal methods, 11, 40–44 Lead Paint Poisoning Prevention Act of 1971, 111 440 Lead (Pb) pollution batteries, 109, 303–311 Clean Air Act, 33 consumer product hazard, 110, 111 criteria pollutant, 28 feasibility issue, 101, 102 paint, 111, 390 radiator repair industry, 332–333, 338– 354 tetraethyl lead, 170–177 workplace hazards, 96 Leak detection and repair (LDAR), 251 Lehr, Lewis, 399 Liability, long-term remediation, 267–268 Liefert, Jerry, 413 Lienhart, Brad, 380 Life cycle analysis (LCA), 183–187, 280– 284, 288, 313–316 Ling, Joseph, 398, 400 Local level, 148 aerosols industry, 378 consumer/industrial product hazards, 118 transportation control policies, 31 water pollution policies, 34 London killer fog of 1952, 27 Louisiana, 212 Love Canal, 43 Lowest achievable emissions rate (LAER), 29 Management/organization issues, industrial, 176–177 Market-based incentive mechanisms, 7, 15–16, 401, 422 Massachusetts, 144–146 Material Safety Data Sheets (MSDS), 134 Maximum available control technology (MACT), 29 McDonald’s, 189–190 McNamara-O’Hara Act of 1966, 98 Media-specific legislation, 25, 50 See also Single-medium basis for regulations Index air pollution, 26–33 executive branch policy-making, 44–49 land disposal methods, 40–44 water pollution, 33–40 Medical Removal Protection, OSHA’s, 342, 344 Methodology For Analyzing the Environmental and Economic Effects of Electric Vehicles: An Illustrative Study (EPA), 284 Methyl butyl ketone, 97 Methylene chloride (METH), 114, 116, 363, 373, 375–376 Methyl-isocyanate (MIC), 251 Methyl-tert-butyl ether (MTBE), 257, 259 Midgeley,Thomas, 171–172 Military facility conversion, 425–426 Minnesota, 396, 410–412 Mobile sources and emissions limitations, 29 Mobil Oil, 189 Modeling requirements, 21 Molina, Mario, 362 Monsanto, 212, 264, 422 Montreal Protocols of 1987, 364 Motors, electric, 298–299 Motor Vehicle Pollution Control Act of 1965, 27 Motor vehicles and air pollution, 29, 30– 31, 175, 286 Movie studios, 183 Moynihan, Patrick, 141–142 Muir,Warren, 66, 67 Multimedia basis for regulations, 14 Nader, Ralph, 111–112 National Air Pollution Control Administration, 45 National Ambient Air Quality Standards (NAAQS), 28, 33 National Association of Manufacturers, 134 National Automotive Radiator Service Association (NARSA), 334–335, 344 National Commission on Product Index Safety, 112 National Conference on Air Pollution, 27 National Emission Standards for Hazardous Air Pollutants (NESHAP), 69 National Environmental Policy Act (NEPA) of 1970, 26, 45, 58 National Fire Protection Association Code, 379 National Hazardous Waste Survey, 240 National Industrial Pollution Control Council, 397 National Institute for Occupational Safety and Health (NIOSH), 98–99, 105, 106, 341, 345–346 National Occupational Exposure Survey (NOES), 106 National Occupational Hazard Survey (NOHS), 106 National Pollutant Discharge Elimination System (NPDES), 36, 37 National Research Council (NRC), 125, 141 National Toxicology Program, 363 National Toxics Campaign, 128 National Water Commission, 37 Natural Resources Defense Council, 362 Navigable waters, pollutant discharges into, 36–37 Nelson, Darby, 133 NESHAP See National Emission Standards for Hazardous Air Pollutants Neurological diseases, 97, 339 New Jersey, 137, 144, 146–147 Nitrites in metal-working fluids, 61 Nitrogen oxides (NOx), 28, 33, 71 Nixon, Richard M., 45–46, 397 Nonbrass radiators, 335–336 Nonchlorinated solvents, 301 Non-point source and emissions limitations, 29 Nontechnological standards, 30–31, 32, 33, 50 Notification procedures of TSCA, 61, 65 NRC See National Research Council 441 Occupational hazards See Workplace hazards Occupational Safety and Health Act (OSH) of 1970, 26, 48, 98–99, 102 Occupational Safety and Health Administration (OSHA) enforcement mechanisms, 108–110 lead pollution, 342–344 OSH and establishment of, 98 problem identification, 105–107 risk assessment, 103–105 standards, establishing, 99–103 Ocean pollution, 35 Office of Management and Budget (OMB), 38, 39, 44, 48, 81, 142 Office of Pollution Prevention and Toxics (OPPT), 65 Office of Solid Waste (OSW), 78, 79 Office of Technology Assessment (OTA), 76, 97, 109, 125–127, 149–150, 424 Office of Toxic Substances, 47 Off-site recycling, 77 Open pits, 11, 40–44 Oregon, 144, 146 Organic solvents, 96 Organization for Economic Cooperation and Development (OECD), 424 Organization/management issues, industrial, 176–177 Original equipment (OE) manufacturers, 334 OSH See Occupational Safety and Health Act OSHA See Occupational Safety and Health Administration OTA See Office of Technology Assessment Ozone depletion, stratospheric, 362–363 Ozone (O3 ), 28, 48 Paint, lead, 111, 390 Paints, spray, 381 Paper producing, 218, 226 442 Particulate matter (PM 10), 28, 33 Perchloroethylene (PERC), 370, 375 Performance standards, 29 Permissible exposure limit (PEL), 103, 104, 342, 373 Perpich, Rudy, 411 Personal protective equipment (PPE), 346–347 Pesticides, 34, 60, 96–97, 111, 112, 361 Peters,Tom, 392 Petrochemical industry, 211, 212, 221 Phenol, 177 Phosphorous, white, 110 Photochemical oxidants, 31 Planning requirements, 21 Plastic, 296–298 Point-source standards, 16, 35–36 See also Prevention, pollution Policy-making process See also Crisis management focus of pollution policies; Definition debates over toxic policies; Media-specific legislation; Single-medium basis for regulations building block concepts, 126 control system, pollution, 10–13, 20–22 executive branch, 44–49 incremental nature of, 17, 34 information’s role in, 18–19 right-to-know proposals, 424 3M, 410–413 Pollution See also Control system, pollution; Economic costs of pollution control/prevention; Prevention, pollution; various subject areas Pollution Prevention Act (PPA) of 1990, 2, 58, 59 ambiguities of, 73, 74–75, 77 reducing waste as focus of, 130 TRI, 137–138 Pollution Prevention Education and Research Center (PPERC), Pollution Prevention Office, 77–78, 79 Polyaromatic hydrocarbons (PAHs), 69 Polychlorinated biphenyls (PCBs), 60, 61 Polyester fiber, 228 Polystyrene foam containers, 118, 189 Index Polyurethane/ABS materials, 297 Post-It Notes, 405–407 Potential responsible parties (PRPs), 43 Precision Valve Corporation, 361 Premanufacture notices (PMNs), 65 Preventing Illness and Injury in the Workplace (OSHA), 109 Prevention, pollution, 49, 50, 58 See also Chemical industry; Electric vehicles (EVs); various subject areas ambiguities of legislation/regulation concerning, 73–85 barriers to, 153–154, 421–426 chemical industry, 263–269 control system vs., 1–5, 13–17, 153– 157 defining, 16 EPA, 14, 59, 130–131 linking terms to policy, 149–152 OSHA, 102 production outcomes and industrial decisionmaking, 197–199 public health officials in California, 32 single-medium basis for regulations, 67–73 state policies, 144–149 TSCA’s lost opportunity, 59–67 water pollution policies, 37 Primary ambient air quality standards, 28 Primary/secondary/tertiary products in chemical industry, 222 Problem identification and priority setting at OSHA, 105–107 Process modifications in chemical industry, 248–262 Process-related wastes/emissions, 237– 245 Proctor & Gamble, 190 Production outcomes and industrial decisionmaking, 197–199 Product life cycles, 183–187, 280–284, 288 Product redesign and raw material substitution for waste reduction, 263– 269 Program-based regulation, 47 Index Program-dominated internal structure, EPA’s, 59 Propellants in aerosols industry, 115–116, 362, 369, 379 Propylene polymerization, 257 Public access to information See Rightto-know proposals Public health See Health issues/standards Public Interest Research Groups (PIRGs), 128 Publicly owned treatment works (POTWs), 36, 37 Public transit development, 32 Quayle, Dan, 81, 142 Radiator repair industry, 332–333 background on, 334–335 control system, pollution, 344–348 eliminating risk, 353–354 exposure and risks, 338–342 OSHA, 342–344 process involved in, 335–338 substitutions, 348–353 Radionuclides, 39 Radium, 110 Randolph, Jennings, 96 Raw material usage in chemical industry, 238–240 Reaction chemistry in reactor technologies, 257 Reaction injection molding (RIM), 297 Reactor technologies, 255–260 Reagan, Ronald, 38, 42, 44, 48, 69, 115 Reasonably available control technology (RACT), 29 Recycling waste, 74, 77, 127 automobiles, 292, 317–318 batteries, 307–311 camera, single-use, 408–409 plastics, 298 Post-It Notes, 406-407 state policies, 48 Red blood cell destruction, 339 Redington, Dennis, 266 Reducing Hazardous Waste Generation—An 443 Evaluation and Call for Action (NRC), 125 Reducing Risk: Setting Priorities and Strategies for Environmental Protection (EPA), 139, 141 Regulations See also Control system, pollution; Media-specific legislation; Policy-making process; Singlemedium basis for regulations; Technology-based standards aerosols industry, 377–381 alternative modes of, 21, 22, 33, 67 ambiguities of pollution prevention policy, 73–85 anti-regulatory backlash, 43, 48–49, 115 classical forms of, 20–21, 30, 49–50 command-and-control format, 15 definition of, 20–21 front-end, 63–64 See also Prevention, pollution generic classes of policy tools, 21–22 multimedia basis for, 14 program-based, 47 Regulatory Analysis and Review Group (RARG), 48 Reilly,William, 79, 80, 139, 421 Renal damage, 339 Reporting requirements, 21, 74–75, 130 See also Toxics Release Inventory (TRI) Reproductive capacity, 97, 340 Research and CAA Amendments, 71 Resource Conservation and Recovery Act (RCRA) chemical industry, 211, 237–238 EPA, 127 exemptions, 136 federal role increased through, 12 hazardous substances/waste, 13, 41–42, 68–69 land disposal, 43–44 Reagan administration, 48 Resource Recovery Act (RRA) of 1970, 40 Respiratory protection, 102, 347 444 Responsible Care program, CMA’s, 196 Rhone-Poulenc (petrochemical plant), 423–424 Right-to-know proposals CMA opposition, 197 definition debates over toxic policies, 131–139 environmental audits, 182 evolution of, 19 OSHA, 106 policy makers influenced by, 424 Pollution Prevention Act, 130 Risk assessment, 63, 103–105, 139–143, 177–180 Rohm and Haas (chemical plant), 60, 178 Rowland, F Sherwood, 362 Roy, Manik, 78–79 Ruckelshaus,William, 46, 49, 141 Safe Drinking Water Act of 1974, 34, 38–39 Safe work practices, 347–348 Sandpaper, wetordry, 390 Schaeffer, Eric, 77, 84 Science Advisory Board, EPA’s, 376 Scientific uncertainty, 31, 179 Scotch Tape, 393 Screening, individualized, 21 Screening/testing and phase-out provisions for Hazardous substances/waste, 58 Secondary ambient air quality standards, 28 Selectivity in reactor technologies, 255 Separation technology in chemical industry, 260 Serious Reduction of Hazardous Waste (OTA), 424 Sheet molding composite (SMC), 297 Shutt, Dave, 407 Sick building syndrome, 226–227 Sierra Club, 74 Sikorski, Gerry, 138 Silent Spring (Carson), 34 Silica/silicosis, 96 Index Sinclair, Upton, 110 Single-medium basis for regulations, 26 See also Media-specific legislation chemical pollution, 60 entrenched nature of, 19 environment and workplace, distinctions maintained between, 95 integrated pollution control contrasted with, 14–15 Pollution Prevention Act, 75 reconfiguring, 67–73 Social engineering, 32 Social Investment Forum, 194 Society of Environmental Toxicology and Chemistry (SETAC), 184, 186 Solder, lead-free, 348–350, 354 Solvents acetone, 381 aerosols industry, 369–370 chlorinated, 301 nonchlorinated, 301, 380 organic, 96 water-based, 381 Source reduction See Prevention, pollution Source Reduction and Recycling Plan, 78–79 Source Reduction and Regulatory Review, EPA’s, 410 Source Reduction Review Project (SRRP), 83–84 Spent catalyst wastes in reactor technologies, 257 Standard Industrial Classification (SIC) Codes, 132, 136, 334, 365 Standard setting, 21 See also Control system, pollution; Policy-making process; Regulations;Technologybased standards air pollution, 28–29 nontechnological, 30–31, 32, 33, 50 OSHA, 99–103 permissible exposure limits, 103, 104, 342, 373 threshold limit values, 100, 135–136, 309 Index State Implementation Plans (SIPs), 28, 30 States aerosols industry, 377, 378 battery recycling laws, 310 consumer/industrial product hazards, 118 definition debates over toxic policies, 143–148 occupational safety and health legislation, 97 prevention, pollution, 411–412 regional emissions limitations defined by, 29 right-to-know proposals, 133 Superfund, 76 transportation control policies, 31 water pollution policies, 34, 35, 37 Stationary sources and emissions limitations, 28 Steel/copper radiators, 335 Stockman, David, 115 Structural analyses of the chemical industry, 269–272 Structural and organizational barriers for pollution prevention/control, 16, 422–423 Structure of consumption for specific commodity chemicals, 227–229 Structure of the Chemical Processing Industries,The, 222 Substance Research Centers, 77 Substitutions in radiator repair industry, 348–353 Sulfuric acid, 69 Sulfur oxides (SOx ), 28, 33, 47, 71 Sullivan Principles, 194 Sunoco, 195 Superfund, 43–44, 49, 76, 77, 115, 131 Supreme Court, U.S., 101–104 Surface water, chemical contamination of, 38 Systems function pollution control framework, 47 Takings, 73 445 Taxes, 16, 21 Technology-based standards, 25 Clean Air Act of 1970, 72 Clinton administration, 143 HAP, 70 incremental nature of pollution policy, 17 innovative pollution control technologies, 46–47 land disposal methods, 41 NESHAP, 69 nontechnological standards vs., 30–31 reactor technologies, 255–259 technocentrism, 19–20 transportation control policies, 32–33 water pollution policies, 37 Technology forcing/stalling, 29 Testing provisions of TSCA, 62–63 Tetraethyl lead (TEL), 170–177 Texas, 212 33/50 program to reduce release of toxic chemicals, EPA’s, 79, 80–83, 142, 396 Thomas, Lee, 49 3M, 3, 264, 365, 422 camera, single-use, 407–409 design and avoidance, 404–405 environmental impacts, 394–396 innovation at, 390–394 Post-It Notes, 405–407 regulatory issues, 410–413 3P program, 389, 397–404 3P (Pollution Prevention Pays) program, 389, 397–404 Threshold limit values (TLVs), 100, 135– 136, 307 Times Beach (Missouri) episode, 117 Tin-based solders, 348–350, 354 Total Exposure Assessment Methodology, EPA’s, 370 Total Quality Environmental Management (TQEM), 425 Toxic chemical pollutants See Hazardous substances/waste Toxicology programs, industrial, 177–180 446 Toxics Release Inventory (TRI) aerosols industry, 372 chemical industry, 211, 212–217, 237–238 critics of, 264 environmentalists, 74–75 Pollution Prevention Act, 130 recycling, 77 right-to-know proposals, 131–139, 424 3M, 394–396 voluntary approach by industry to accomplishing prevention goals, 80 workplace hazards, 106–107 Toxic Substances Control Act (TSCA) of 1976, 2, 12, 41, 47–49, 58–67, 102, 178 Toxics Use Reduction Act (TURA), Massachusetts, 144–146 Trace contaminants in reactor technologies, 255 Tradeable permits, 16, 37, 401 Training in pollution prevention, 155– 156 Transportation, Department of, 112, 377 Transportation control policies, 30–33 Treatment, waste, 36–37, 74, 83, 126 See also Control system, pollution TRI See Toxics Release Inventory Trichloroethylene (TCE), 370 1,1,1-Trichloroethane (TCA), 363–364, 369–370, 375 Trihalomethanes (THMs), 39, 218 TSCA See Toxic Substances Control Act (TSCA) of 1976 2% budgetary program for pollution prevention activities, EPA’s, 79–80 UCLA Pollution Prevention Center, 107 Uncertainty, scientific, 31, 179 Unfinished Business: A Comparative Assessment of Environmental Problems (EPA), 139 Unfunded mandates, 73 Union Carbide, 180, 181 Unit operations approach for reducing wastes in chemical industry, 248–262 Index Urea formaldehyde foam insulation, 114 U.S Standard Industrial Classification codes, 223 Use reduction, toxics See Prevention, pollution Valve systems in aerosols industry, 368–369 Ventilation systems and lead exposure, 345–346 Venture team concept at 3M, 392 Vinyl chloride, 14–15, 96, 114, 212, 228 Viscusi,W Kip, 107 Volatile organic compounds (VOCs), 301, 372, 378–379, 413 Voluntary approach by industry to accomplishing prevention goals, 16, 80–81, 85, 115, 142, 198, 422 See also 3M Wash-Healy Act of 1936, 98, 100 Waste minimization, EPA’s report on, 125–128 See also Prevention, pollution Waste oil as dust suppressant, 117 Waste Reduction Act, 73, 76 Water-based solvents, 381 Water pollution, 33–40, 72–73 Watt, James, 48 West Virginia, 135 Wet basis and mass of waste generation, 238 Wetlands protection, 35 Wetordry sandpaper, 390 Whole facility approach, 84 Wildlife threatened by pollution, 11 Workplace hazards acceptable risk, 103–105 aerosols industry, 373–374 batteries, 307, 309 definition debates over toxic policies, 128 enforcement mechanisms, 108–110 historical review, 95–98 Occupational Safety and Health Act, 98–99 Index Occupational Safety and Health Administration, 99–107 radiator repair industry, 332–333, 338– 354 safe work practices, 347–348 tetraethyl lead, 172–174 3M, 396 worker participation in pollution prevention, 424–425 Yield data in chemical industry, 238, 240–244 Zinc-based solders, 350, 354 447 Island Press Board of Directors CHAIR Susan E Sechler Executive Director, Pew Global Stewardship Initiative VICE-CHAIR Henry Reath President, Collector’s Reprints, Inc SECRETARY Drummond Pike President, The Tides Foundation TREASURER Robert E Baensch Senior Consultant, Baensch International Group Ltd Peter R Borelli Executive Vice President, Open Space Institute Catherine M Conover Lindy Hess Director, Radcliffe Publishing Program Gene E Likens Director,The Institute of Ecosystem Studies Jean Richardson Director, Environmental Programs in Communities (EPIC), University of Vermont Charles C Savitt President, Center for Resource Economics/Island Press Peter R Stein Managing Partner, Lyme Timber Company Richard Trudell Executive Director, American Indian Resources Institute [...]... national environmental strategy RANIA SABTY has a master’s degree in public health and is currently a Ph.D candidate in the UCLA Department of Environmental Health Sciences, focusing on industrial hygiene and occupational health and safety PETER SINSHEIMER is a senior research associate with the UCLA Pollution Prevention Education and Research Center He is a Ph.D candidate in the UCLA Department of Urban... the creation of a hazardous waste tracking system.This new federal role, moreover, led to an increasing centralization and concentration of functions and activities in relation to both regulatory agendas and a new and rapidly expanding waste management or “environmental” industry that arose in response to such regulatory requirements Establishing federal policies on pollution, wastes, and hazards, however,... standards Industrial chemicals, primarily organic solvents and metals, were found in measurable quantities in drinking water wells and groundwater aquifers, creating a new and unanticipated environmental threat Dump sites, including many that previously had been abandoned, posed substantial risks to nearby communities, even forcing evacuations of houses and neighborhoods Serious occupational hazards,... Maureen Smith, Janice Mazurek, Pamela Yates,Tamira Cohen, and Peter Sinsheimer, each of whom authored or coauthored one or more chapters Janice Mazurek also played a crucial role in restructuring and ultimately cohering the overall manuscript Research assistance for several of the chapters was provided by PPERC research associates Deborah Fryman, Andrea Gardner, Peter Hein, Joseph Powers, Helene Wagner,... structural and organizational analyses of pollution prevention presented in Parts I and II, we conclude that pollution prevention still lacks coherence in terms of its definition, institutional implementation, and day-to-day application Reducing Toxics is a collaboration among faculty and research associates affiliated with the Pollution Prevention Education and Research Center (PPERC), an interdisciplinary... audit manager for a Fortune 500 company She is also a Ph.D candidate in the UCLA School of Public Health and was a senior research associate with the UCLA Pollution Prevention Education and Research Center Acknowledgments This book is a collaborative effort of faculty and researchers associated with the UCLA Pollution Prevention Education and Research Center The Center was established in 1991 to address... Education and Research Center and is an assistant professor in the UCLA Department of Urban Planning In 1994 she was on leave from UCLA as a senior policy analyst in the Office of Science and Technology Policy At OSTP she xi xii Contributors was engaged in a wide range of projects, including evaluating management and legislative strategies for toxics, and reviewing the White House’s proposal for a national... to signal a major break from the particular regulatory formats and the conceptual frameworks of pollution control that had become rigid over nearly two decades, as local authorities, then states, and then the federal government attempted to address the unwanted environmental byproducts of an advancing industrial society Pollution prevention also was viewed as a response to the failures and limitations... increasing political prominence of environmental issues.Within a remarkably short period of time, a new national environmental policy or pollution control system was constructed, based on a series of new laws enacted after 1970 and new regulatory agencies established in part to carry out the mandates specified in those acts These new legislative mandates and regulatory activities focused on various forms... gravity for policymaking and instead appeared to mask certain fundamental differences in approach regarding the role of policy in addressing questions of production design and decisionmaking As a widely heralded new policy framework, pollution prevention increasingly became defined in contrast to pollution control, and the language of fundamental change—even of paradigm shift—in turn became pervasive