Toxic Substances: EPA Needs More Reliable Source Reduction Data and
Progress Measures (Chapter Report, 09/23/94, GAO/RCED-94-93).

In 1990, Congress passed the Pollution Prevention Act, which authorizes
the Environmental Protection Agency (EPA) to help companies implement
source reduction techniques. The act also requires companies to report
their results to EPA's Toxic Release inventory, which includes data on
releases of more than 300 toxic chemicals. This report reviews EPA's (1)
progress in implementing source reduction reporting requirements, (2)
results under a voluntary program to reduce emissions of 17 highly toxic
chemicals, and (3) activities to disseminate source reduction
information to meet state and industrial needs.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-94-93
     TITLE:  Toxic Substances: EPA Needs More Reliable Source Reduction 
             Data and Progress Measures
      DATE:  09/23/94
   SUBJECT:  Toxic substances
             Industrial facilities
             Reporting requirements
             Pollution control
             Waste management
             Data collection operations
             Environmental policies
             Industrial pollution
             Information dissemination operations
             Environmental monitoring
IDENTIFIER:  EPA Toxics Release Inventory Program
             EPA Industrial Toxics Project
             EPA 33/50 Program
             Hazardous Pollution Prevention Planning Act of 1993
             
**************************************************************************
* This file contains an ASCII representation of the text of a GAO        *
* report.  Delineations within the text indicating chapter titles,       *
* headings, and bullets are preserved.  Major divisions and subdivisions *
* of the text, such as Chapters, Sections, and Appendixes, are           *
* identified by double and single lines.  The numbers on the right end   *
* of these lines indicate the position of each of the subsections in the *
* document outline.  These numbers do NOT correspond with the page       *
* numbers of the printed product.                                        *
*                                                                        *
* No attempt has been made to display graphic images, although figure    *
* captions are reproduced. Tables are included, but may not resemble     *
* those in the printed version.                                          *
*                                                                        *
* A printed copy of this report may be obtained from the GAO Document    *
* Distribution Facility by calling (202) 512-6000, by faxing your        *
* request to (301) 258-4066, or by writing to P.O. Box 6015,             *
* Gaithersburg, MD 20884-6015. We are unable to accept electronic orders *
* for printed documents at this time.                                    *
**************************************************************************


Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Health and the Environment,
Committee on Energy and Commerce, House of Representatives

September 1994

TOXIC SUBSTANCES - EPA NEEDS MORE
RELIABLE SOURCE REDUCTION DATA AND
PROGRESS MEASURES

GAO/RCED-94-93

More Reliable Source Reduction Data Needed


Abbreviations
=============================================================== ABBREV

  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  OMB - Office of Management and Budget
  TRI - Toxic Release Inventory

Letter
=============================================================== LETTER


B-255921

September 23, 1994

The Honorable Henry A.  Waxman
Chairman, Subcommittee on Health
 and the Environment
Committee on Energy and Commerce
House of Representatives

Dear Mr.  Chairman: 

In response to your request, this report discusses the Environmental
Protection Agency's (EPA) efforts to reduce toxic chemical pollution
at its source and to assess source reduction progress.  As agreed, we
are providing you with information on EPA's implementation of source
reduction reporting required by the Pollution Prevention Act of 1990,
efforts to promote voluntary source reduction activities among
industrial facilities, and dissemination of source reduction
information to meet state and industrial needs. 

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after the date of this letter.  At that time, we will send copies of
the report to the appropriate congressional committees and
subcommittees; the Administrator, EPA; the Director, Office of
Management and Budget; and other interested parties.  We will make
copies available to others upon request. 

This work was performed under the direction of Edward A.  Kratzer,
Assistant Director, Environmental Protection Issues, who can be
contacted on (202) 512-6553 if you or your staff have any questions. 
Major contributors to this report are listed in appendix II. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental Protection
 Issues


EXECUTIVE SUMMARY
============================================================ Chapter 0


   PURPOSE
---------------------------------------------------------- Chapter 0:1

Stressing the importance of establishing a national environmental
management strategy focusing on preventing pollution at its source,
in 1990 the Congress enacted the Pollution Prevention Act.  The act
authorizes the Environmental Protection Agency (EPA) to assist
companies in implementing source reduction techniques and requires
companies to report their results to EPA's Toxic Release Inventory,
which includes data on releases of over 300 toxic chemicals.  The
Chairman, Subcommittee on Health and the Environment, House Committee
on Energy and Commerce, asked GAO to review EPA's (1) progress in
implementing source reduction reporting requirements, (2) results
under a voluntary program to reduce emissions of 17 highly toxic
chemicals, and (3) activities to disseminate source reduction
information to meet state and industrial needs. 


   BACKGROUND
---------------------------------------------------------- Chapter 0:2

EPA has developed mandatory and voluntary approaches to implementing
the Pollution Prevention Act.  The agency requires companies to
report their source reduction activities when submitting their annual
reports to the Toxic Release Inventory and encourages them to
participate in the voluntary Industrial Toxics Project, popularly
known as the 33/50 Program.  The companies participating in this
program are encouraged to reduce emissions of 17 toxic chemicals by
33 percent by 1992 and 50 percent by 1995, preferably by source
reduction but also by using more conventional methods, such as
pollution control devices and recycling and reuse.  The participating
companies are encouraged to provide information on their source
reduction plans, activities, and results to EPA so it can use
successful efforts to promote widespread use of new preventive
approaches or technologies.  EPA also promotes pollution prevention
by providing planning guidance and operating a source reduction
information clearinghouse for the states and industry and other
potential users. 


   RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:3

EPA has implemented the Pollution Prevention Act's reporting
requirements by adding a source reduction and recycling report to the
Toxic Release Inventory.  This report, section 8 of EPA's Toxic
Release Inventory Reporting Form R, obtains information on companies'
source reduction activities but not on the quantities of waste
prevented or reduced through such activities.  Although EPA assesses
progress in source reduction by comparing annual changes in the
reported data on production and waste generated, GAO questions the
reliability of such comparisons because of several problems with the
data's accuracy, including annual changes in companies' methods of
estimating waste. 

EPA has made progress in implementing voluntary pollution-prevention
activities, but the results of these activities are uncertain.  For
example, the companies that participate in the 33/50 Program
collectively produce most of the wastes targeted by the program and
have reported substantial reductions in their emissions; however,
most of the reduced emissions cannot be readily attributed to the
program because substantial reported reductions occurred before the
program or were reported by nonparticipants.  Nor can the reported
reductions be attributed to source reduction methods, as opposed to
less preferable methods such as improved pollution control devices,
because participating companies are not required to link their
reported reductions to the methods used and generally do not provide
such information to EPA.  The agency is evaluating the program's
results and will assess companies' use of source reduction methods. 

A key element in EPA's pollution-prevention strategy is providing
states and industry with the technical information needed to
implement source reduction programs.  However, industry and states
have expressed a need for additional information to better enable
them to identify and make use of source reduction technology.  EPA
has initiated several actions to expand and improve its efforts to
disseminate source reduction information. 


   PRINCIPAL FINDINGS
---------------------------------------------------------- Chapter 0:4


      SOURCE REDUCTION DATA ARE
      NEEDED TO MEASURE PROGRESS
-------------------------------------------------------- Chapter 0:4.1

EPA proposed adding source reduction quantity information to the
Toxic Release Inventory.  However, in carrying out its review
responsibilities under the Paperwork Reduction Act, the Office of
Management and Budget (OMB) objected to EPA's requesting information
on the quantities of waste prevented or reduced through source
reduction because of the additional reporting burden this would
impose on industry.  OMB suggested that EPA might sample companies,
rather than require all companies to report the data to the
inventory.  While OMB approved the interim use of the Toxic Release
Inventory reporting form in May 1992, EPA was required to omit
questions on the quantities of waste prevented or reduced. 

Lacking such information, EPA gauges progress in source reduction by
comparing annual changes that companies report on production and
waste generated for Toxic Release Inventory chemicals.  However, such
comparisons are not reliable indicators of source reduction because
EPA cannot determine whether reported reductions in waste are due to
improved environmental performance or to other factors, such as
annual changes in companies' production or methods of estimating
waste. 

Before resubmitting the Toxic Release Inventory reporting form to OMB
for final approval, EPA plans to redesign the form to improve the
areas in which it believes the data obtained are incomplete,
inaccurate, or unreliable.  In redesigning the form, EPA also will
consider obtaining additional data needed to measure progress in
source reduction.  An EPA official told GAO that if the agency does
not request the source- reduction quantity data in the redesigned
form, it will consider using a survey of industrial facilities. 
Whether obtained through the inventory or a survey, data on the
quantities of waste prevented or reduced are needed for EPA to
accurately measure progress in source reduction. 


      RESULTS OF VOLUNTARY EFFORTS
      ARE UNCERTAIN
-------------------------------------------------------- Chapter 0:4.2

EPA's 33/50 Program is the agency's primary voluntary source
reduction activity.  Over 1,200 companies responsible for about 62
percent of the emissions targeted participate in the program, and EPA
has reported more than 595 million pounds in toxic waste reductions
from 1988 through 1992, which exceeds EPA's 1992 national goal for
the 17 chemicals targeted by the program.  However, not all of the
reported reductions are readily attributable to the program.  For
example, about 40 percent of the reductions occurred before the
program's initiation in February 1991, and about 26 percent were
reported by the more than 6,800 companies not participating in the
program, which account for about 38 percent of the total targeted
emissions.  Furthermore, substantial reductions were reported for
Toxic Release Inventory chemicals not targeted by the 33/50 Program,
suggesting that production changes or other factors unrelated to
commitments made under the program may be largely responsible for the
companies' reported reductions. 

Moreover, although the 33/50 Program emphasizes the importance of
source reduction, EPA did not require companies to report whether
their reductions were achieved through source reduction or other
methods because the agency wanted to impose on companies as little
burden as possible as a way of encouraging participation. 
Consequently, EPA does not have the information needed to monitor and
assess source reduction under the voluntary program and to share with
industry and the states successful approaches that were used to
prevent or reduce waste at its source.  Recognizing the need for such
information, EPA initiated a 33/50 Program evaluation that includes
assessing factors influencing reported emissions reductions,
including the effects of source reduction activities. 


      EPA NEEDS TO IMPROVE
      DISSEMINATION OF SOURCE
      REDUCTION INFORMATION
-------------------------------------------------------- Chapter 0:4.3

The Pollution Prevention Act and EPA's implementation strategy
recognize that the exchange of information is a key factor in
promoting source reduction practices.  To facilitate the adoption of
such practices, EPA has developed and disseminated pollution
prevention planning guidance to industry and established a
clearinghouse for providing information on source reduction
technology to the states, industry, and others. 

However, states and industrial users want more comprehensive
information on source reduction than is currently available, and EPA
is taking appropriate steps to identify and address these concerns. 
For example, EPA is performing a needs assessment among its
information clearinghouse users and is working with states to
establish priorities among their needs for source reduction
information. 


   RECOMMENDATION
---------------------------------------------------------- Chapter 0:5

To evaluate progress in preventing or reducing pollution at its
source in accordance with the Pollution Prevention Act, GAO
recommends that the Administrator, EPA, either through the Toxic
Release Inventory or a survey of a sample of companies, obtain and
analyze data on the quantities of waste prevented or reduced through
source reduction activities. 


   AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:6

GAO discussed the facts in this report with EPA officials, including
the Director of the Environmental Assistance Division, Office of
Pollution Prevention and Toxics.  While these officials generally
agreed with the accuracy of the factual information in this report,
they suggested changes to clarify and update information pertaining
to the agency's pollution-prevention strategy and related activities. 
The officials also suggested that GAO provide additional information
in order to more fully reflect the accomplishments of the 33/50
Program, especially during the last 2 years.  GAO made such changes
where appropriate.  In addition, GAO made changes to improve the
presentation of the issues discussed in this report.  As requested,
GAO did not obtain written agency comments on a draft of this report. 


INTRODUCTION
============================================================ Chapter 1

Despite American industry's extensive use of pollution control
technology, millions of tons of toxic chemical waste continue to be
released into the environment each year, posing risks to the
environment and to the health of workers, consumers, and the public. 
According to the Environmental Protection Agency (EPA), in 1992 the
manufacture or use of about 320 chemicals that are monitored by the
agency generated over 37 billion pounds of toxic waste, and about 3.2
billion pounds were released into the environment.\1

For many years, emphasis has been placed on "end-of-pipe" pollution
controls to treat, store, and dispose of waste, with varying degrees
of success.  Recognizing the limitations of such controls to reduce
releases of waste into the environment, in 1990 the Congress,
stressing the importance of establishing a national environmental
policy focused on preventing pollution, enacted the Pollution
Prevention Act. 


--------------------
\1 1992 Toxics Release Inventory, Public Data Release, EPA
745-R-94-001 (Apr.  1994). 


   THE POLLUTION PREVENTION ACT
   FOCUSES ON SOURCE REDUCTION
---------------------------------------------------------- Chapter 1:1

The Pollution Prevention Act established a national policy that
pollution should be prevented or reduced at its source.  Pollution
that cannot be prevented should be recycled or treated in a safe
manner, and disposal or other releases should be used only as a last
resort.  The act directed EPA to develop and implement a strategy to
promote source reduction, which the act defined as any practice that
(1) reduces the amount of any hazardous substance, pollutant, or
contaminant from entering any waste stream or being released into the
environment prior to recycling, treatment, or disposal and (2)
reduces the hazards to public health and the environment associated
with the release.  Source reduction includes practices such as
modifying equipment, technology, processes, or procedures;
redesigning products; and substituting less-toxic raw materials. 

The act further required EPA to (1) establish a computerized source
reduction clearinghouse that contains information to help firms and
other users to implement source reduction activities and (2) expand
reporting under the Toxic Release Inventory (TRI) to include
pollution prevention information.  The inventory, which was created
by the Congress in 1986 under the Emergency Planning and Community
Right-to-Know Act, is a major information system to which industries
report annually to EPA and the states on their facilities' estimated
releases of hundreds of chemicals.  The Pollution Prevention Act
requires each facility that submits information to the inventory to
report also on (1) the quantity of toxic chemicals entering any waste
stream prior to recycling, treatment, or disposal; (2) changes in a
chemical's production or use from the facility's previous report; and
(3) the source reduction practices used, if any, to reduce chemical
waste.  EPA compiles the data and makes them available to the public. 


   EPA'S STRATEGY EMPHASIZES
   VOLUNTARY ACTIONS
---------------------------------------------------------- Chapter 1:2

To carry out the national pollution prevention policy required by the
1990 act, in January 1991 EPA established a strategy based on
promoting source reduction in industry, through regulatory and
voluntary efforts and information sharing.\2 The strategy identified
the TRI, as modified by the act, as the agency's principal source of
data and the standard means for assessing and measuring progress in
source reduction. 

EPA's strategy reflects two major objectives.  The first is to make
pollution prevention a central part of the agency's mission of
protecting human health and the environment.  Accordingly, EPA is
attempting to integrate pollution prevention initiatives into its
activities, programs, and operations.  EPA believes that its
mainstream activities, such as regulatory development, permitting,
inspections, and enforcement, must reflect a commitment to reduce
pollution at the source and minimize the transfer of waste from one
medium (air, land, or water) to another.  (App.  I summarizes
examples of these initiatives.)

The second objective is to establish a pollution prevention ethic
within American industry by encouraging companies to voluntarily plan
and implement approaches to pollution prevention and to share their
successes with others through a program of information sharing,
public recognition, and awards.  EPA's Industrial Toxics Project,
also known as the 33/50 Program, is the agency's principal initiative
directed at seeking industry's voluntary commitments to achieve
specific goals in pollution prevention within a specified period. 
The 33/50 Program is intended to (1) encourage companies to take
voluntary action to identify pollution prevention opportunities for
17 targeted chemicals; (2) measure success on the basis of reductions
in toxic releases into the environment from 1988 through 1995, as
reported to the TRI; and (3) obtain demonstrable results to promote
the widespread use of new technologies and preventive approaches. 


--------------------
\2 U.S.  Environmental Protection Agency Pollution Prevention
Strategy, EPA (Washington, D.C.:  Jan.  1991). 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
---------------------------------------------------------- Chapter 1:3

The Chairman, Subcommittee on Health and the Environment, House
Committee on Energy and Commerce, asked us to review EPA's (1)
progress in implementing source reduction reporting requirements, (2)
results under the voluntary program to reduce the emissions of 17
highly toxic chemicals, and (3) activities to disseminate information
on source reduction to meet the states' and industry's needs. 

To determine EPA's progress in implementing source reduction
reporting requirements, we interviewed EPA officials and reviewed the
agency's documentation on its proposed source reduction and recycling
report under the TRI (section 8 of EPA's Toxic Release Inventory
Reporting Form R).  We also reviewed the comments of state, industry,
and public interest organizations on the proposed requirements and
reviewed the Office of Management and Budget's (OMB) response to
EPA's proposed report.  In addition, we visited four
states--Illinois, Massachusetts, Minnesota, and Oregon--that we had
identified in our previous report\3 as having laws promoting the
reduced use of toxic chemicals.  We obtained the views of
environmental agency officials in these states on state pollution
prevention reporting and on information they need from EPA to meet
their needs. 

To assess EPA's efforts to promote voluntary pollution prevention by
industry and to reduce emissions under the 33/50 Program, we
interviewed officials of EPA's Office of Pollution Prevention and
Toxics, who are responsible for administering pollution prevention
activities.  We also reviewed relevant reports and documents,
including status reports for the 33/50 Program.  We also compared
information reported to the TRI by the companies in the 33/50 Program
and other respondents. 

To review EPA's activities to disseminate information, we reviewed
EPA's guidance for performing pollution prevention assessments and
EPA's evaluation of the information clearinghouse established by the
Pollution Prevention Act of 1990.  We also interviewed EPA officials
responsible for developing and disseminating the guidance and for
improving the effectiveness of the clearinghouse.  In addition, we
obtained state officials' views on the usefulness of EPA's pollution
prevention clearinghouse and of the pollution prevention information
in the TRI.  We also relied on information provided in our report on
EPA's use of pollution prevention grants, provided under the 1990
act, to encourage source reduction as part of the states' programs.\4
In addition, we reviewed EPA documents on EPA-state information
exchange issues and interviewed EPA officials responsible for
coordinating with and monitoring of the states' programs. 

We performed our work from August 1992 to June 1994, in accordance
with generally accepted government auditing standards.  We discussed
the facts in this report with EPA officials, including the Director
of the Environmental Assistance Division, Office of Pollution
Prevention and Toxics.  While these officials generally agreed with
the accuracy of the factual information in this report, they
suggested changes to clarify and update information pertaining to the
agency's pollution prevention strategy and related program
activities.  The officials also suggested that we provide additional
information in order to more fully reflect the accomplishments of the
33/50 Program, especially during the last 2 years.  We have made such
changes where appropriate.  In addition, we made changes to improve
the presentation of the issues discussed in this report.  As
requested, we did not obtain written agency comments on a draft of
this report. 


--------------------
\3 Toxic Substances:  Advantages of and Barriers to Reducing the Use
of Toxic Chemicals (GAO/RCED-92-212, June 17, 1992). 

\4 Pollution Prevention:  EPA Should Reexamine the Objectives and
Sustainability of State Programs (GAO/PEMD-94-8, Jan.  25, 1994). 


SOURCE REDUCTION DATA ARE NEEDED
TO EVALUATE PROGRESS
============================================================ Chapter 2

Before the enactment of the Pollution Prevention Act, manufacturing
facilities reported to EPA the quantity of chemicals released into
the environment at the reporting facility and the quantity treated
and disposed of off-site.  With the passage of the act, EPA expanded
the data that facilities are required to report to include additional
waste management information, such as the quantity of chemicals
recycled or burned for their energy value and the activities
initiated to reduce pollution at its source.  However, facilities do
not report the quantity of reductions in toxic chemical emissions
that have actually been achieved through source reduction methods. 

Without information on source reduction quantities, it is not known
whether reduced emissions are due to improved environmental
performance or to other factors, such as changes in production levels
or the use of alternative chemicals that may be as harmful as those
for which reductions are reported.  EPA is evaluating the need for
additional source reduction data. 


   EPA IS OBTAINING ADDITIONAL
   INFORMATION TO MEASURE PROGRESS
   IN PREVENTING POLLUTION
---------------------------------------------------------- Chapter 2:1

The Pollution Prevention Act shifted policy emphasis by stressing
methods for reducing waste at its source and otherwise preventing the
creation of pollutants, rather than on controlling or treating
releases of pollutants.  To implement this policy, on September 25,
1991, EPA proposed in the Federal Register\1 a rule requiring that
the companies reporting to the TRI provide information on their
source reduction and recycling activities, uses of specific
chemicals, amounts of on-site releases and off-site transfers, and
methods of on-site waste treatment.  In proposing the rule, EPA
stated that the Pollution Prevention Act reporting requirements are
intended to ensure that sufficient information is available to
evaluate the progress made by EPA and others in implementing source
reduction.  EPA said that: 

     "The information will be used by EPA, the States, the public,
     and industry to track the results of the full hierarchy of
     environmental protection -- source reduction, recycling,
     treatment, and disposal -- and the progress due to source
     reduction.  This will help the Agency to determine whether
     pollution prevention can succeed on a voluntary basis or whether
     a more enforcement-oriented approach will be more effective in
     reducing the use of toxic chemicals at the source.  This will
     also be useful in evaluating the Agency's progress in
     implementing its Pollution Prevention Strategy."

To evaluate this progress, EPA believed that it was necessary to
collect information on the quantities of chemicals that would have
entered waste streams if companies had not implemented source
reduction.  A number of states with their own source reduction
programs supported this proposal, arguing that the public should have
access to information on the quantities of waste prevented. 

As required, EPA requested OMB approval to obtain the source
reduction quantity and other information that EPA proposed adding to
the TRI.  However, in performing its responsibilities under the
Paperwork Reduction Act, OMB pointed out that the Pollution
Prevention Act required reporting only on the practices used to
achieve source reduction, not on the quantities of waste resulting
from the source reduction practices.  OMB suggested that EPA might
instead obtain the needed data from a sample of companies, noting
that, in this way, EPA could obtain the data it needed in a less
burdensome manner. 

In May 1992, OMB approved a modification of EPA's proposed source
reduction and recycling report for use on an interim basis while EPA
completes its planned redesign of the TRI reporting form based on
discussions with manufacturers, environmental groups, and other
interested parties.\2 However, in using the OMB modified report EPA
was required to omit questions on the quantities of waste prevented
through source reduction methods. 

In May 1993, EPA released its 1991 TRI data that included for the
first time information based on the source reduction and recycling
report.  The data reflected substantial reductions in industrial
releases into the nation's environment but showed that a considerable
volume of toxic waste was still being generated.  The data for 1991
showed that 38 billion pounds of waste were generated and managed by
industry through activities such as recycling and energy recovery, an
amount equal to more than 11 times the 3.4 billion pounds of these
generated wastes that were reported as releases into the
environment.\3 In announcing the inventory data, the EPA
Administrator said that: 

     "Even though emissions of chemicals are decreasing, we don't see
     a similar downward trend in waste generation.  The data
     projected for 1992 and 1993 suggest that generated waste will be
     flat or even increase slightly.  The data also suggest that
     recycling will decline while quantities of toxic chemicals being
     treated will rise.  If these projections are true, this is a
     disturbing trend."

In April 1994, EPA released the 1992 TRI results that indicated
continued cause for concern.  The 1992 data showed that industrial
facilities had generated over 37 billion pounds of waste.  The
facilities also indicated that their 1993 and 1994 reports of total
generated wastes may reflect increases. 


--------------------
\1 56 Federal Register 48475 (Sept.  25, 1991). 

\2 On May 19, 1992, OMB approved the source reduction and recycling
report form that EPA used to collect pollution prevention information
for reporting years 1991, 1992, and 1993.  EPA may continue to use
this form until it promulgates revisions pursuant to law.  A TRI
official told us that EPA expects to complete such revisions by late
1996 or early 1997. 

\3 EPA's 1991 TRI states that a release is an on-site discharge of a
toxic chemical to the environment--air, land, or water--at a
reporting facility. 


   DATA ARE NOT RELIABLE FOR
   MEASURING SOURCE REDUCTION
   PROGRESS
---------------------------------------------------------- Chapter 2:2

Lacking information from companies on the estimated quantities of
waste prevented through the source reduction methods they reported
using, to gauge progress in source reduction, EPA must rely on
estimates of annual production and related toxic waste.  For example,
if a company's production is unchanged but its waste is reduced, a
reported source reduction may have occurred.  However, such
comparisons may not be reliable for evaluating the progress of source
reduction, for the reasons discussed below. 

Even though approximately 70,000 chemicals are used commercially in
the United States, companies report annually to the TRI on production
and related waste for only about 320 of these chemicals. 
Consequently, the companies may maintain or even increase their usage
of toxic chemicals while concurrently reducing the chemicals that are
reported to EPA.  For example, substituting for a chemical on the
inventory by using another equally or more toxic chemical would
reduce the quantity of toxic waste reported.  However, the
substitution would not reduce hazards to public health or the
environment and would not be a source reduction. 

Furthermore, the companies' TRI reports on waste generated do not
include information on the amount of chemicals present in the
products manufactured and sold, even though such chemicals become
waste when products are used and discarded.  Consequently, without
information on the quantities of waste prevented or reduced, EPA has
no way to determine the impact of the companies' actions to reduce
the concentration of toxic chemicals present in their products. 

Moreover, the companies often do not have data systems sophisticated
enough to provide reliable estimates of production and related waste. 
Some manufacturers have over 100 different processes for a changing
mix of products, each requiring different amounts of chemicals and
producing different quantities of waste.  These manufacturers often
do not have data systems to account for individual relationships
among each product manufactured and the chemicals used, emitted into
the environment, recycled, treated, and otherwise managed.  For
example, in commenting on EPA's source reduction and recycling
report, the state of California pointed out that analyzing changes in
annual production and chemical waste is not useful for its major
aerospace and petrochemical industries, given their inability to
account for the impacts of annual changes occurring among production
units and chemical specifications for individual products. 

Lacking such data, the companies use estimation techniques to
calculate the interrelationships between production and waste. 
However, as state and other users of TRI data have pointed out, the
companies often change their estimation techniques from one year to
the next, preventing data users from accurately evaluating the
progress of source reduction. 

EPA acknowledges that its ability to measure source reduction is
limited because the TRI does not provide information specific enough
to explain reasons for changes in quantities of reported releases. 
In issuing its 1991 and 1992 inventory data, EPA noted that, while
the data can give some indication of source reduction, changes in
waste quantities also result from other causes.  For example, in a
recently completed survey, EPA contacted over 1,200 industrial
facilities that had informed the agency of changes in generated waste
between 1989 and 1990.  On the basis of the facilities' survey
responses, EPA found that nearly 70 percent attributed some portion
of their emissions increases or decreases to production level
changes. 


   EPA IS CONSIDERING THE NEED FOR
   ADDITIONAL SOURCE REDUCTION
   DATA
---------------------------------------------------------- Chapter 2:3

Before resubmitting its redesigned TRI reporting form to OMB for
approval, EPA plans to analyze the areas in which it believes the
data are incomplete, inaccurate, or otherwise not reliable.  EPA will
also consult with manufacturers, environmental groups, and other
organizations, including the National Advisory Council for
Environmental Policy and Technology.\4 An EPA official estimated that
the revised reporting form will not be available for another 2 to 3
years, given the time that will be required to complete their
deliberations and the regulatory review process. 

EPA officials told us that they remain concerned about their ability
to accurately measure progress in source reduction and recognize that
information on the quantities of waste reduced or prevented through
source reduction would enable the agency to more accurately measure
such progress.  According to these officials, in redesigning the TRI
reporting form, the agency will consider changes in the data
collection methodology needed to measure progress in source
reduction, including the methods for obtaining data on the quantities
of source reduction.  However, since the Pollution Prevention Act
does not require the agency to obtain such data, these officials are
not certain that the data will be included in the redesigned
reporting form, which will be largely based on consensus views
obtained from OMB, industry, environmental groups, and others
participating in the regulatory review process.  In addition, as an
option to obtaining the quantity information through the inventory
reporting form, an EPA official told us that the agency will consider
obtaining it by surveying industrial facilities. 


--------------------
\4 The Council is a federal advisory committee organized under the
Federal Advisory Committee Act to provide information and advice to
the EPA Administrator and other EPA officials on policies for
managing the environment.  The Council's members include senior-level
representatives of a wide range of EPA's constituents, including
business and industry; academic, educational, and training
institutions; federal, state, and local government agencies and
international organizations; environmental groups; and nonprofit
entities. 


   CONCLUSIONS
---------------------------------------------------------- Chapter 2:4

While EPA has taken steps to make the TRI more comprehensive, the
inventory does not collect data on quantities of waste prevented due
to source reduction methods companies reported using.  In the absence
of such data, EPA assesses the extent of progress in source reduction
by comparing changes in the companies' annual estimates of their
production and waste generated.  However, EPA itself acknowledges its
limited ability to gauge progress in source reduction on the basis of
such estimates, because annual variations in the companies'
production and data on generated waste may likely reflect changes in
the companies' methods of estimating waste or in economic conditions,
rather than reflecting improved environmental performance. 

Although EPA recognizes the limitations of the data in the inventory
for measuring progress in source reduction, the agency has not
committed itself to collecting additional data because the Pollution
Prevention Act does not require it to do so.  OMB has suggested that
a less burdensome way to collect source reduction data might be
through a survey of a sample of companies.  Whether through a sample
or through the inventory, given the inadequacies of source reduction
data currently available through the inventory, in our opinion
additional data are needed in order to provide a credible basis for
evaluating progress in source reduction. 


   RECOMMENDATION
---------------------------------------------------------- Chapter 2:5

To evaluate progress in preventing or reducing pollution at its
source in accordance with the Pollution Prevention Act, we recommend
that the Administrator, EPA, either through the Toxic Release
Inventory or a survey of a sample of companies, obtain and analyze
data on the quantities of waste prevented or reduced through source
reduction activities. 


EPA'S VOLUNTARY POLLUTION
PREVENTION APPROACH HAS PRODUCED
UNCERTAIN RESULTS
============================================================ Chapter 3

EPA's strategy for implementing the Pollution Prevention Act consists
largely of encouraging industrial polluters to voluntarily adopt
pollution prevention practices.  In carrying out this strategy, the
agency has the Industrial Toxics Project, a voluntary waste reduction
program known as the 33/50 Program, which EPA has described as its
showcase for source reduction activities. 

Over 1,200 companies have joined the 33/50 Program, which was
initiated to reduce emissions of 17 highly toxic chemicals that are
used extensively in commerce.  The companies that have joined the
program account for most of the 17 chemicals' emissions and have been
encouraged by EPA to review their operations to identify source
reduction opportunities.  However, while industry reported that the
targeted emissions have been reduced overall by about 40 percent from
1988 through 1992, an amount that exceeds the program's 1992 national
reduction goal set by EPA, most of the reductions cannot be readily
attributed to the program.  Nor does EPA know the extent to which the
reductions are attributable to source reduction, as opposed to other
factors, such as pollution control devices, reduced production, or
changes in reporting methods. 


   BACKGROUND ON EPA'S VOLUNTARY
   EMISSIONS REDUCTION PROGRAM
---------------------------------------------------------- Chapter 3:1

EPA initiated the 33/50 Program in February 1991, describing it as a
key component in the agency's national pollution prevention strategy
required by the Pollution Prevention Act of 1990.  Since then, EPA
has invited over 8,100 industrial companies to participate in the
program by volunteering to reduce their emissions of the 17 targeted
chemicals in the TRI.  The goals for reduction were set by EPA at 33
percent, or 486 million pounds, by 1992 and 50 percent, or 737
million pounds, by 1995, as measured against a 1988 baseline.  EPA
encourages the companies to use source reduction methods, but other
methods of reducing emissions, such as waste treatment, are
acceptable under the program.  EPA also encourages companies to
report their source reduction plans, activities, and results to EPA
in order that the agency can use their demonstrable efforts to
promote the widespread use of new preventive approaches or
technologies. 

EPA's choice of the 17 chemicals covered by the program was based on
several factors.  For one thing, EPA chose contaminants that were to
be regulated under the provisions of the Clean Air Act Amendments of
1990, to ensure that companies participating in the voluntary program
would also be eligible for credit under the early emissions reduction
provision of the law.\1 Another reason was that the 17 chemicals are
among the more than 300 high-priority toxic chemicals used
extensively in commerce and reported annually to the TRI. 

Once companies agree to participate, they are able to (1) set their
own reduction goals, which can be higher or lower than EPA's overall
national goals; (2) use end-of-the-pipe controls rather than source
reduction activities to reduce releases (even though EPA encourages
source reduction); and (3) choose 1988 or any subsequent year as a
baseline.  The only program commitment a participant must make is to
reduce emissions of the chemicals:  It does not have to specify how
it will honor this commitment.  Participants that reduce their
emissions are publicly recognized. 

EPA believed that the companies would be willing to participate in
the 33/50 Program for a variety of reasons.  Besides being able to
use reductions under the 33/50 Program to qualify for the early
reduction incentive of the Clean Air Act, EPA reasoned that the
companies would be interested in the cost-savings that might result
from the production efficiencies that are used to reduce emissions. 
Furthermore, the agency believed that the companies would see this
participation as an opportunity to gain public recognition of their
environmental awareness and commitment to environmental management. 
And finally, EPA provided the companies with great flexibility in
reducing emissions and required few prerequisites for joining the
program. 


--------------------
\1 Under the Clean Air Act Amendments' early reduction provision,
companies receive additional time to comply with applicable emissions
standards if they significantly reduce their emissions before EPA
proposes such standards. 


   IMPACT OF THE 33/50 PROGRAM IS
   UNCERTAIN
---------------------------------------------------------- Chapter 3:2

Many of the nation's largest chemical polluters have joined the 33/50
Program, and the TRI shows that substantial reductions have been
reported in toxic emissions measured under the program.  Nonetheless,
most polluters do not participate in the program, and most of the
emissions reductions that have been reported are not readily
attributable to the program or to source reduction activities. 


      PARTICIPATION IS LIMITED AND
      THE REASONS FOR REDUCTIONS
      ARE UNKNOWN
-------------------------------------------------------- Chapter 3:2.1

A priority for the 33/50 Program has been to obtain the participation
of the companies producing the largest quantities of emissions of the
17 chemicals; thus far, 1,242 companies producing about 62 percent of
the 1988 emissions have joined the program.  While participation in
the program is substantial, over 6,800 companies--or about 85 percent
of those invited--have chosen not to join.  Furthermore, while EPA
continues to solicit companies to participate, a dwindling number
have agreed to do so.  During 1993, for example, EPA invited 902
companies but only 38--or about 4 percent--joined.  The agency has
not determined the companies' reasons for declining to participate in
the program. 

The emissions levels reported for the 17 chemicals covered by the
33/50 Program have fallen steadily from 1988 through 1992, the latest
year for which complete information is available.  As shown in figure
3.1, from 1988 through 1992, the 33/50 companies and other companies
reporting to the TRI reduced their total emissions of the 17
chemicals from about 1,486 million pounds to about 890 million
pounds, a 40 percent reduction.  However, substantial reductions were
also reported for other chemicals in the inventory that have not been
targeted by the 33/50 Program.  Figure 3.1 shows that such chemicals
decreased from about 4,982 million pounds in 1988 to about 3,310
million pounds in 1992, nearly a 34-percent reduction. 

   Figure 3.1:  Emissions of 33/50
   Program Chemicals Compared to
   Total TRI Emissions, Less 33/50
   Chemicals, 1988 Through 1992

   (See figure in printed
   edition.)

\a First year of the 33/50 Program initiated by EPA in February 1991. 

\b Total emissions of 33/50 Program chemicals include those reported
by companies not participating in the program. 

Source:  GAO's analysis of EPA data. 

EPA points out, however, that the rate of reported reductions since
the program was put in place in 1991 has been greater for 33/50
Program chemicals than for other inventory chemicals.  EPA data show
that in 1991 and 1992, overall chemical reductions totaled about 358
million pounds for the 33/50 chemicals and about 468 million pounds
for other inventory chemicals--reductions of about 29 percent and 12
percent, respectively, from 1990 levels.  While EPA recognizes that a
considerable portion of the reductions were reported by
nonparticipants, the agency points out that participating companies'
rate of reported reductions after the program began in 1991 is larger
than for nonparticipants.  EPA data show that in 1991 and 1992, the
reductions reported by participants totaled about 246 million pounds,
or a reduction of about 34 percent from 1990 through 1992.  For the
same period, EPA data show that nonparticipants' reported reductions
totaled about 112 million pounds, or a reduction of about 22 percent. 

In addition, EPA has reported that waste from the 17 chemicals has
been reduced by 596 million pounds, exceeding the 33/50 Program's
interim national reduction goal of 490 million pounds by 1992, as
shown in figure 3.2.  However, not all of the reported reductions are
readily attributable to the program.  About 40 percent of the
reductions occurred from 1988 through 1990, prior to the initiation
of the program in 1991.  Furthermore, about 155 million pounds, or
about 26 percent of the reductions were reported by firms that do not
participate in the program.  In effect, without counting the
reductions achieved by nonparticipating firms, the 33/50 Program
would not have met its interim goal. 

   Figure 3.2:  Cumulative
   Participant and Nonparticipant
   Reductions of 33/50 Program
   Chemical Emissions Compared to
   Program's National 33-Percent
   Goal, 1988 Through 1992

   (See figure in printed
   edition.)

\a First year of the 33/50 Program initiated by EPA in February 1991. 

\b The 33/50 Program's 33-percent national emissions reduction goal
is 490 million pounds from 1988 through 1992. 

Source:  GAO's analysis of EPA data. 

The substantial overall emissions reductions from 1988 through 1992
reported for both the 33/50 chemicals (40 percent) and other TRI
chemicals (34 percent) suggest that factors other than commitments
under the program may have been largely responsible for the
companies' reductions.  Furthermore, as discussed in chapter 2, an
EPA sample of TRI reports for 1989 and 1990 found that nearly 70
percent of the surveyed facilities attributed some portion of their
emissions increases or decreases to production level changes.  The
survey also found that while source reduction was a significant
factor, other factors such as economic conditions and measurement and
reporting changes can also substantially affect the quantities of
emissions reported. 


      REDUCTIONS MAY NOT BE
      ATTRIBUTABLE TO SOURCE
      REDUCTION
-------------------------------------------------------- Chapter 3:2.2

A key objective of the 33/50 Program is to encourage companies to use
pollution prevention practices, rather than end-of-the-pipe controls,
to achieve the targeted emissions reductions.  Likewise, EPA
encourages the companies participating in the program to report their
source reduction plans, activities, and results to EPA so that the
information can be made available to other companies through the
agency's information dissemination activities, such as its source
reduction clearinghouse,\2 discussed in chapter 4.  Nonetheless, the
companies generally have not provided such information to EPA, and
EPA has chosen not to require it because the agency did not want to
discourage companies from participating in the program. 
Consequently, EPA does not know whether or the extent to which the
33/50 companies have achieved their emissions reductions through
source reduction methods, as opposed to improved pollution control
devices and other treatment methods. 

EPA recognizes that better information is needed to determine the
impact of the 33/50 Program and has initiated an evaluation of the
program's results that is being conducted by INFORM, a nonprofit
environmental research and education organization,\3 under a
cooperative agreement with EPA.  The evaluation is assessing the use
of source reduction to meet the 33/50 Program's goals; the extent to
which companies' participation in the program contributed to EPA's
meeting its targeted reductions; and the effect of specific program
features, such as flexibility in methods for reducing emissions, on
companies' decisions to join the program and on their reduction
activities. 

INFORM's evaluation methodology will use statistical sampling to
assess the factors influencing 33/50 chemical emissions reductions,
including source reduction methods, and will compare and contrast TRI
reports from participating and nonparticipating facilities.  The
methodology will also use supplementary survey and interview data
from other research projects that INFORM is performing on pollution
prevention.  INFORM expects to issue a report on the evaluation's
preliminary results in the fall of 1994, covering the 1991 and 1992
inventory reports, and to issue annual follow-up reports covering the
1993 through 1995 inventories. 


--------------------
\2 The clearinghouse established under the Pollution Prevention Act
to make available to the public information on management, technical,
and operational approaches to source reduction. 

\3 INFORM conducts case study research of pollution prevention
programs and practices at manufacturing facilities in the United
States and has issued the following reports on source reduction: 
Cutting Chemical Wastes, INFORM, Inc.  (New York, N.Y.:  1985) and
Environmental Dividends:  Cutting More Chemical Wastes, INFORM, Inc. 
(New York, N.Y.:  1992). 


   CONCLUSIONS
---------------------------------------------------------- Chapter 3:3

The initiation of EPA's 33/50 Program was a significant step toward
obtaining American industry's voluntary commitment to reduce toxic
chemical emissions, and companies have reported substantial
reductions in the 17 chemicals targeted by the program.  Nonetheless,
most companies invited have not joined the program, even though EPA
has given them great flexibility and required few prerequisites for
joining.  Furthermore, while substantial reductions have been
reported in the emissions of the 17 chemicals covered by the 33/50
Program, the program's impact is uncertain, given that (1) the
reductions are partly attributable to companies that do not
participate in the program; (2) much of the reductions reported
occurred before the program was initiated; and (3) the program
participants are not required to report on their source reduction
approaches and results.  We believe that the 33/50 Program evaluation
EPA has initiated should provide a basis to more effectively gauge
the program's impact by assessing the extent to which source
reduction and other factors influence reported emissions reductions. 


EPA NEEDS TO MORE EFFECTIVELY
DISSEMINATE INFORMATION TO PROMOTE
SOURCE REDUCTION
============================================================ Chapter 4

EPA recognizes that a key factor in achieving industrial source
reduction is the exchange of information between government and
industry.  Thus, among the key elements of EPA's pollution prevention
strategy is the development of (1) guidance to help businesses assess
their operations and develop plans for implementing source reduction
techniques, (2) a computerized information clearinghouse for source
reduction data and technologies, and (3) an effective partnership
with the states in providing businesses with source reduction
information and technical assistance.  EPA has taken steps to
implement each of these elements in its strategy, but an internal
agency study and our review have found that the agency needs to
improve the quantity and quality of its source reduction data. 


   EXTENT OF POLLUTION PREVENTION
   PLANNING IS UNKNOWN
---------------------------------------------------------- Chapter 4:1

EPA has developed and disseminated pollution prevention planning
guidance to industry to facilitate the adoption of source reduction
practices.  The development of pollution prevention plans is
voluntary, and EPA does not know the extent to which industry has
implemented the agency's planning guidance.  Three of the four states
we visited during our review require companies in the state to
prepare pollution prevention plans.  While no similar federal
requirement exists, legislation has been proposed to require
companies reporting to the TRI to prepare plans and establish goals
for pollution prevention. 


      PLANNING GUIDANCE HAS BEEN
      DEVELOPED AND DISSEMINATED
-------------------------------------------------------- Chapter 4:1.1

Reducing the use of toxic chemicals by changing production processes
or operations, or by replacing such chemicals with nontoxic raw
materials, clearly benefits the public and the environment, which
otherwise would be exposed to higher levels of toxic releases. 
Reducing pollution can also benefit industry to the extent that it
lowers the cost of waste disposal, pollution control, and future
liabilities.  Nevertheless, some companies will be reluctant to make
capital investments, such as purchasing new equipment needed to
reduce pollution, when the cost-effectiveness of such decisions is
uncertain. 

To encourage and assist companies to determine the cost-effectiveness
of projects, in May 1992 EPA issued its Facility Pollution Prevention
Guide,\1 designed to assist companies in developing pollution
prevention programs.  The guide provides a comprehensive approach for
identifying pollution prevention opportunities and for developing a
plan that describes the operations producing, using, or releasing
hazardous or toxic materials; the types and amount of waste the firm
is attempting to reduce; and pollution prevention activities. 

EPA distributed about 20,000 copies of the guide to companies and
various groups interested in pollution prevention, including state
and local governments and trade and industrial associations. 
However, an EPA official told us that the agency does not know the
extent to which companies, including those participating in the 33/50
Program, have used the guide. 


--------------------
\1 Facility Pollution Prevention Guide, EPA 600-R-92-088, (May 1992). 


      PROPOSED FEDERAL LEGISLATION
      WOULD REQUIRE POLLUTION
      PREVENTION PLANS SIMILAR TO
      SOME STATES' REQUIREMENTS
-------------------------------------------------------- Chapter 4:1.2

Three of the four states we visited during our review require
companies operating in the state to prepare pollution prevention
plans.  The state officials that we interviewed told us that their
planning requirements were necessary to determine which companies
need technical assistance in identifying and implementing source
reduction activities.  In our January 1994 report on state pollution
prevention programs,\2 we pointed out that about one-third of the 88
state programs surveyed in our review require companies to submit
documentation on pollution prevention planning activities and
results. 

Although the Pollution Prevention Act does not require industry to
prepare pollution prevention plans, legislation has been introduced
in the 103rd Congress to that effect.  The Hazardous Pollution
Prevention Planning Act of 1993 (S.  980) would require the
businesses that report to the TRI to prepare plans that consider
pollution prevention options and establish 5-year goals for pollution
prevention.  While the companies would not be required to implement
source reductions, they would be required to report to EPA on the
progress they are making toward such reductions and explain cases in
which progress is less than expected.  In addition, EPA would be
required to identify industrial categories in which technical
assistance is needed before additional progress can be made. 


--------------------
\2 Pollution Prevention:  EPA Should Reexamine the Objectives and
Sustainability of State Programs (GAO/PEMD-94-8, Jan.  25,1994). 


   SOURCE REDUCTION CLEARINGHOUSE
   IS NOT MEETING NEEDS
---------------------------------------------------------- Chapter 4:2

To foster the growth of pollution prevention programs in government
and industry, EPA has established a clearinghouse that provides
source reduction information and technology data.  The Pollution
Prevention Act directed EPA to establish the clearinghouse to (1)
compile information, including a computerized data base that contains
information on management, technical, and operational approaches to
source reduction; (2) serve as a center for source reduction
technology transfer; (3) provide outreach to further the adoption of
source reduction technologies; (4) gather information on the
operation and success of federally aided state source reduction
programs; and (5) make all such data available to the public in a
manner that permits any person to enter and retrieve the data. 

In establishing the clearinghouse, EPA modified an existing
clearinghouse that it had created in the late 1980s to encourage the
minimization of waste.  The clearinghouse consists of a repository
for hard-copy documents and an electronic data base, initially
established in 1988 to disseminate information on minimizing waste. 
EPA officials told us that the clearinghouse provides some
information on source reduction activities that the companies have
reported to the TRI or to the 33/50 Program but that few companies
have provided such information. 

In 1991, EPA performed an assessment of the clearinghouse's
activities.  The assessment identified a number of weaknesses,
including the following: 

  A needs assessment of the clearinghouse's users had not been
     performed since its inception in 1988 as a source of waste
     minimization information, and EPA did not know if companies were
     receiving adequate information to implement pollution prevention
     opportunities. 

  EPA has been slow to add source reduction studies to the
     clearinghouse, and only a small portion of case studies and
     publications focus on source reduction approaches. 

EPA's evaluation also showed that several state officials were not
satisfied with the amount and quality of source reduction data in the
automated data base.  For example, some states believed that the case
study abstracts were too general to be useful in responding to
companies' requests for technical assistance in implementing source
reduction in their operations. 

Officials we contacted in three of the four states we visited also
believe that EPA's clearinghouse is not adequate to meet their needs. 
One concern is that the clearinghouse's automated data base often
lacks critical information on the costs and benefits of implementing
source reduction technologies.  Another concern is that source
reduction technologies are changing rapidly, and some of the
information in the clearinghouse is outdated.  According to one state
official, it is crucial that the clearinghouse contain the most
up-to-date information in order for companies to achieve the greatest
environmental impact.  Officials told us that, because of problems
with EPA's clearinghouse, they rely on their own technical assistance
programs to provide companies with information needed to carry out
source reduction activities. 

To address the weaknesses noted in its internal evaluation, EPA has
(1) established an advisory committee to provide guidance and to
establish priorities\3 and (2) reorganized clearinghouse
responsibilities to more clearly assign the responsibilities for
expanding and maintaining the automated and hard-copy components of
the clearinghouse.  In addition, EPA recently reported that the
National Roundtable of State Pollution Prevention Programs\4

is working under a cooperative agreement with EPA to determine how
the clearinghouse can meet the needs of its users.  A Roundtable
official told us that as part of its efforts, the Roundtable plans to
complete pilot studies in the Northeast and the Midwest to create
regional data base systems that maintain technical information on
each region's industries.  For example, the Northwest region could
maintain information on the paper and pulp industry and the Midwest
region on the foundry industry. 

To ensure that the regional systems are complete, the Roundtable
plans to use the information currently in the clearinghouse, as well
as state and other data bases in the region.  While developing the
regional data bases, the Roundtable also plans to create
cross-references that will link information for each industry
included in the data bases. 


--------------------
\3 The committee is part of EPA's National Advisory Council for
Environmental Policy and Technology; its members include
representatives of state governments, industry, and public interest
groups. 

\4 A national forum to promote multimedia pollution prevention.  The
forum meets twice each year to exchange technical and program
information. 


   BETTER STATE-EPA COORDINATION
   IS NEEDED TO PROMOTE SOURCE
   REDUCTION
---------------------------------------------------------- Chapter 4:3

EPA views the states as being at the forefront of the pollution
prevention movement and providing a direct link to industry to
provide source reduction information.  Accordingly, EPA's pollution
prevention strategy recognizes that the states must play an important
role and that closer coordination is needed, especially at a time of
severely limited federal and state resources. 

The states view EPA as the national manager of TRI data used in their
pollution prevention programs and as a source of guidance.  In the
four states we visited, officials told us that they believe that EPA,
through its routine participation at state organizations' national
and regional meetings, is generally aware of the types of source
reduction information that their programs collect.  Nonetheless, as
discussed below, the officials said that more needs to be done to
share and coordinate federal and state information. 

The Pollution Prevention Act requires EPA to collect and compile
information on the operation and success of federally aided state
source reduction programs as part of EPA's source reduction
clearinghouse activities.  However, state officials generally told us
that they have not coordinated their actions to implement pollution
prevention programs with EPA and that they are not aware of any
agency data analyses involving the use of the states' source
reduction information. 

The officials also said that they do not provide any planning or
reporting information to EPA, except for progress reports that the
states must complete as a result of receiving pollution prevention
grants from EPA.\5 In a recent review of federally aided pollution
prevention programs, we found that the data in the required progress
reports were unsuitable for determining program progress and that
many state programs do not sufficiently emphasize source reduction.\6
We recommended that EPA strengthen the requirements for the state
grant program evaluations and establish criteria for measuring the
success of businesses' source reduction efforts. 

An EPA advisory council and an EPA task force also recently studied
opportunities for improving federal and state program coordination to
enhance the mutual benefits and importance of building effective
state pollution prevention programs and to enhance the states'
capacity to administer their programs.  Both reports highlighted the
importance of EPA and the states' taking steps to effectively
integrate their programs and sharing information to fully meet the
needs and concerns that were ranked at the federal and state
levels.\7 The EPA Administrator has acknowledged such concerns and
has committed the agency to increasing the dissemination of
information to promote pollution prevention and track progress and to
working with states to build a national network of prevention
programs. 


--------------------
\5 The Pollution Prevention Act of 1990 authorizes EPA to provide
matching grants to states for programs that promote source reduction
techniques by businesses.  The grantees are required to make
information generated under the grants available to EPA for its use
and for dissemination to others through the Pollution Prevention
Information Clearinghouse EPA established under the 1990 act. 

\6 Pollution Prevention:  EPA Should Reexamine the Objectives and
Sustainability of State Programs (GAO/PEMD-94-8, Jan.  25, 1994). 

\7 Building State and Local Pollution Prevention Programs, State and
Local Environment Committee, National Advisory Council for
Environmental Policy and Technology, EPA 130-R-93-001 (Dec.  1992). 
Report of the Task Force to Enhance State Capacity, Strengthening
Environmental Management in the United States, EPA (Washington, D.C.: 
Apr.  1993). 


   CONCLUSIONS
---------------------------------------------------------- Chapter 4:4

EPA has recognized that the exchange of information is a key element
in promoting source reduction.  Although EPA has developed guidance
to help companies plan source reductions and a clearinghouse to help
firms and states identify source reduction opportunities, the states
and industrial information users said that they need more
comprehensive information.  We believe that EPA has made a
conscientious effort to identify concerns about source reduction data
and that the agency is taking appropriate corrective actions through
various initiatives, such as performing a clearinghouse needs
assessment and working with states to establish priorities for source
reduction information.  We believe that these actions, in conjunction
with implementing the recommendations in our January 1994 report on
corrective measures for state pollution prevention programs, would
improve EPA's performance in carrying out its Pollution Prevention
Act responsibilities. 


EPA'S EFFORTS TO INTEGRATE
POLLUTION PREVENTION INITIATIVES
INTO THE AGENCY'S ACTIVITIES,
PROGRAMS, AND OPERATIONS
=========================================================== Appendix I

The Pollution Prevention Act of 1990 established a new national goal
for environmental protection:  to reduce or eliminate waste at its
source, rather than trying to control it after the fact.  To advance
this goal, EPA has attempted to implement efforts designed to improve
companies' understanding of the costs of pollution and the benefits
of source reduction and to encourage them to voluntarily take source
reduction actions.  Following is information on several of the major
initiatives that EPA has taken. 

Enforcement Actions.  EPA has used its enforcement program's
settlement process to identify and implement pollution prevention
activities.  EPA has reduced penalties to companies that have
violated environmental laws, in exchange for the companies'
implementing pollution prevention projects that yield environmental
benefits. 

Source Reduction Review Project.  Under this project, EPA is to
consider source reduction measures during the development of air,
water, and hazardous waste standards affecting certain industry
categories.  EPA is to focus its review efforts on a key list of
regulations mandated by the Clean Air Act, Clean Water Act, and
Resource Conservation and Recovery Act during the earliest stages of
the regulation development and test different approaches to fostering
source reduction. 

Grant Programs and Demonstration Projects.  EPA has used grants to
encourage pollution prevention.  For example, EPA has developed
agencywide guidance that (1) provides states with the flexibility to
use multimedia grants to support prevention projects and (2) requires
accountability through annual accomplishment reports prepared by its
regional offices.  In addition, EPA earmarks 2 percent of its fiscal
year contract dollars for innovative demonstration projects that have
pollution prevention as their primary goal.  All offices within EPA
can compete for the funds, and many of the projects funded represent
joint efforts between offices and/or regions. 

Design For The Environment.  Through this program, EPA can help
industry design products and processes in ways that eliminate or
minimize the creation of pollution.  For example, EPA can provide
information about chemical risks to businesses so that they can weigh
the use of one chemical against another.  EPA also can encourage
companies to develop voluntary action plans to build environmental
considerations into the design of safer chemicals, products,
technologies, and processes by focusing on less toxic substitutes. 

New Chemicals Program.  EPA incorporates pollution prevention in
reviewing new chemicals under the authorities of the Toxic Substances
Control Act.  When manufacturers submit a new chemical for EPA's
review, the agency can require pollution prevention plans for
substances that involve an unreasonable risk concern, possible high
exposures/releases, and pollution prevention potential.  Such plans
provide an opportunity for companies to reduce or eliminate toxic
chemicals in manufacturing and commerce before the chemicals are used
to create products and eventually become hazardous waste. 

In addition, under EPA's Alternative Synthetic Pathways Project, the
agency is to identify alternatives to the process used to synthesize
certain new chemicals.  EPA is to conduct pollution prevention
reviews to assist in minimizing the generation of toxic chemicals and
to identify specific opportunities for implementing pollution
prevention methods to mitigate and control risks over the chemicals'
life-cycles. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II


   RESOURCES, COMMUNITY, AND
   ECONOMIC DEVELOPMENT DIVISION,
   WASHINGTON, D.C. 
-------------------------------------------------------- Appendix II:1

Bernice Steinhardt, Associate Director
J.  Kenneth McDowell, Assignment Manager


   CHICAGO REGIONAL OFFICE
-------------------------------------------------------- Appendix II:2

Harriet Drummings, Evaluator-in-Charge
Mary D.  Feeley, Site Senior

