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Summary of Industry Representatives Listening Session

National Dialogue On Access to Environmental Information
U.S. Environmental Protection Agency
Washington, D.C.
May 6, 2008

Quick Summary - Industry Representatives would like to have:

Improved access to regulatory compliance information.

Improved data quality and more information about the context of the data that are provided.

“Smart,” interactive compliance tools.

Better knowledge of the information contained on www.epa.gov . Outreach could be improved through information intermediaries.

Short information pieces: one-pagers, executive summaries, and fact sheets.

Customized Web portals.

Information and delivery systems that are customized to account for the different needs of large and small businesses.

A key component of the Environmental Protection Agency’s National Dialogue on Access to Environmental Information is a series of facilitated listening sessions to elicit input on the types of environmental information that EPA’s stakeholders use, how they use it, and their preferred formats, channels, and venues for obtaining this information. This report summarizes inputs from a National Dialogue Listening Session with industry representatives from the Washington, D.C. area. The Appendix at the end of this document provides information about the participants, including their job titles, affiliations, job descriptions, and how they use environmental information in their work.

Types of Environmental and Public Health Information that Participants Use

Representatives of industry and trade associations identified the types of environmental information and specific topics that are most important in their work. Overall, the participants are especially interested in easy access to clear, up-to-date, and relevant regulatory information. Another key concern is the quality of EPA’s data and information. They are also interested in accessing databases, product safety information, educational and background materials on select environmental issues, and EPA operational information, and would like easier access to EPA staff.

Participants emphasized that all regulated entities require easy and comprehensive access to regulatory information. They agreed that clear guidance and interpretation of environmental laws are crucial to their compliance. However, they also noted that there are significant differences in the ways small and large companies access such information.

Types of Information of Interest to Industry Representatives:
  • Regulatory information and standards

  • Compliance guidance

  • Information describing level of data quality

  • Databases

  • Product safety

  • Background and education materials

  • Access to EPA staff

  • Budgetary information

For example, representatives of large companies pointed out that because they are subject to a wide variety of regulations, they employ environmental attorneys to ensure regulatory compliance. In addition, they provide compliance training programs to their employees and generate specialized guidance materials. Consequently, employees of these companies are less likely to consult www.epa.gov directly for regulatory information and instead seek advice from their legal teams and other company compliance experts.

In contrast, small businesses and plant managers of larger companies who are directly responsible for submitting emissions data and information on chemical use are more likely to refer to EPA’s regulatory guidance materials, and need easy access to information on regulations and compliance measures to help them navigate the complex regulatory landscape. Small businesses in particular would benefit from a clearer structure and easier access to information regulations and compliance. Nevertheless, one respondent noted that very small businesses are not big users of environmental information. Their largest information needs are tax and healthcare related.

Another important aspect of the industry representatives’ business operations is to inform concerned consumers about product safety and health risk information. The public wants to know what levels of a pollutant are considered safe – or pose an environmental and/or health risk. Therefore, manufacturers want EPA to provide information on the human health risks associated with certain products [e.g., Bisphenol A (BPA) in baby bottles], which they can pass on to their customers. They indicated that EPA needs to provide the proper context for this information – for example, when presenting emissions data, EPA should relate reported levels of pollutants to thresholds and permissible levels.

The group agreed that, in general, the public has unrealistic expectations of industry with regard to environmental protection and controls, and that EPA leaves it to the public to interpret data, and to figure out for themselves what it really means. They felt that as a result, industry often “looks bad” and suggested that the public would obtain a more balanced view if EPA adopted a proactive role and presented “digested” information, such as data analyses and interpretations rather than raw data sets. Such information should be written in language that is easily understood by the average consumer. “One should not need a Ph.D.” to decipher EPA summaries on toxicological information posted on primary pages, although more detailed studies and research findings should be made available in a section entitled Additional Resources or by clicking on a For More Information Go To link.

One respondent pointed out that in the past the EPA Report on the Environment (ROE) provided a good overview of the linkages between business activities and the environment. However, the 2007 report (note that the 2008 ROE was published on May 20, 2008 after the industry listening session) does not manage to convey a clear message, and instead seems “like a big tossed salad.” Another respondent argued that the U.S. has comparatively high environmental standards relative to the rest of the world and that other countries have fewer and less stringent regulations. He would like the EPA Report on the Environment to provide examples of what other countries do and compare the U.S. state of the environment to that of other countries. He indicated that a lack of international context has led the public to believe that pollution levels in the U.S. are disproportionately high.

Overlaying all of these issues is a call for improved data quality and better documentation of EPA data. Users of EPA information expect the Agency to present unbiased facts that allow them to put into perspective the information disseminated by the media and environmental and public interest groups, who often follow a particular agenda and present interpretations of their own.

Good information matters because it translates to money.

Several participants lamented the lack of information on the level of certainty associated with EPA data sets, and suggested that the Agency include information on uncertainty with its data. They pointed out that data can have significant influence on business decisions – and public perception of the industry – and can carry financial implications. One participant illustrated this with the example of the Data Quality Act. He said that his company had contracted with a private laboratory to assess a company-owned Superfund site and found large discrepancies between EPA’s assessment of the site and the findings of the contractor. Such discrepancies have potentially large implications for clean-up costs. The participant stressed that industry takes clean-up very seriously and that businesses are not looking for “the cheapest way out.” He said that their sites will be remediated in any case, but that all efforts need to be backed up with solid, high-quality data.

Another example is EPA’s Chemical Assessment and Management Program (ChAMP) [http://www.epa.gov/CHAMP]. Under this program, EPA evaluates the human health and environmental risks associated with over 6,500 chemicals. However, the deadline imposed for this effort [2012] seems too ambitious. Some suspect that the risk assessments are driven by time, and that “quality is taking a backseat.” EPA must place more emphasis on data quality and, if necessary, expand the deadline.

Several participants suggested that it is also important for EPA to be transparent and document how it obtains data. For example, EPA developed a specific method of analysis for its effluent guidelines to put the data into context. However, industry analysts were not able replicate EPA’s methodology or interpret its findings, which caused significant confusion. To avoid a similar situation in the future, the industry respondents suggested that EPA seek input from its stakeholders in the development of new guidelines.

In addition, they urge EPA to work with its stakeholders to improve the manner in which data are collected and analyzed. One participant recounted a negative experience he had with EPA sampling at one of his facilities. Facility staff did a split sample every time EPA sampled their site, and sent them to two different labs. The results obtained at these laboratories were strikingly different from the results EPA reported. The participant suspected that this was in part due to a lack of understanding about proper testing specifications at the labs.

One respondent thought that EPA should use a set of predetermined criteria – or guidelines — to evaluate all data. For example, the 2007 Report on the Environment (ROE) clearly specifies evaluation criteria that determine what should or should not be included in the report. The ROE criteria are good because they have undergone considerable scrutiny from large numbers of stakeholders, and the process was transparent. Establishing similar criteria for other data sets would improve the level of confidence in the data and delineate limitations for its use. The participants also said that program integration across the Agency with regard to data delivery is important. Data collections need to be consistent. They conceded that not all collections are under OEI’s purview and that it might be difficult for OEI to manage databases across the Agency.

Respondents noted that EPA has missed a chance to be a leader in terms of data quality, and needs to focus its efforts on improving its data and restoring credibility with its stakeholders. Participants also encouraged the Agency to improve the turnaround time for the publication of its database and reports – however, they indicated EPA must do this without sacrificing the quality of the product. If EPA succeeds, people will pay closer attention to EPA, its data, and its views.

Another issue raised in the context of data quality is that meta data should include the data’s pedigree, including information on the purpose for which the data were collected and how the data can be used. Respondents expressed concern that some users of EPA data may use it incorrectly (e.g., by combining different data sets for a purpose not originally intended), and that EPA needs to be aware of this problem and be clear on how to use Agency information.

I just want to know who is in charge of this issue and who to talk to  - information that should be right up front.

The respondents felt strongly that EPA needs to improve direct access to its staff and to increase the transparency of its operations. They would like to have access to office organizational charts that allow them to identify and contact appropriate staff more readily. “One-click” access to staff contact information would increase transparency and improve stakeholder interaction with EPA. Others noted that they are interested in EPA’s budget information and would like to know what the funding levels are for the various offices and specific programs.

Uses of Environmental and Public Heath Information

Industry representatives primarily use environmental and public health information to:

Formats for Environmental and Public Health Information

Industry representatives mainly work with EPA databases and frequently access EPA guidance documents and fact sheets. They confirmed that they like to obtain information in electronic format and stressed that technical information should be brief and to the point (i.e., fact sheets and executive summaries). They are less interested in lengthy reports or journal articles.

Several industry association representatives noted that they often respond to member inquiries by pointing people to EPA fact sheets, one-pagers, and executive summaries of larger reports. Short documents focus on the “high points” of a topic and are easy to read. Also, good one-pagers include links to additional information and relevant regulations. One participant asked that EPA create a portal to all the fact sheets and one-pagers sorted by category. Currently, fact sheets are not always easy to find. One has to look at the sites of different programs and offices to “hunt them down.”

When asked to name specific actions EPA could take to improve access to information on www.epa.gov, participants made the following suggestions:

Channels and Venues for Delivery of Environmental and Public Health Information

Overall, participants agreed that the Web is the best tool for disseminating information (although they noted that they also obtain environmental compliance information from journals and Inside EPA), but noted that stakeholders must become better educated about the contents of www.epa.gov as it pertains to their business activities. As in other listening sessions, the industry representatives expressed dissatisfaction with EPA’s search engine. They agreed that www.epa.gov contains a vast amount of information, including data, analyses, and regulatory guidance, but that it is difficult to find the needed information. They commented that it is easier to use Google than to search the EPA Web site.

There is a ton of data [on www.epa.gov], but a paucity of information. …  you never find what you need.

The participants pointed out that access to regulatory compliance information and pertinent guidance documents is often cumbersome, and expressed the desire for more streamlined and customized ways to retrieve such information

Businesses need simple guidance tools (e.g., “smart systems”) to assist them in their regulatory compliance efforts. They also stressed the need for contextual and customizable information, including a Business Web portal. The group also recommended that EPA improve its information delivery mechanisms to better serve the needs of its stakeholders.

Participants noted that businesses operate and think differently than regulatory agencies or lawyers. For instance, if a company wants to find out if its effluents are in compliance, they do not intuitively consult the Clean Water Act (CWA) – “they might not even know about the CWA.” It would therefore be helpful for EPA to develop “smart systems” to assist businesses with their reporting and compliance requirements. A “smart system” was described as an interactive software program that guides users through a number of steps and – based on user input – generates customized guidance or reports.

Participants suggested that “smart technologies” could enable a more targeted delivery of EPA’s information products. For example, if somebody is looking for information on health risks associated with particular chemicals, it would be helpful if links to related pages were displayed along with the risk information (i.e., applicable regulations, trends, background information, methodologies and guidance materials). The information should be tailored to specific stakeholders and user groups and categorized by level of complexity (e.g., one-page fact sheets for the general public or students vs. scientific reports and regulatory support documents).

When asked to provide examples of “smart systems” or Web sites that had an intuitive structure, one participant mentioned TurboTax®. TurboTax® does not provide regulatory compliance assistance, but it is easy to use and could serve as a model for an EPA compliance tool. Another example is the European Chemicals Agency’s REACH Navigator [http://reach.jrc.it/navigator_en.htm]. One participant added that OSHA has recently introduced an online regulatory compliance tool, but she did not have any experience with it. [http://www.osha.gov/dts/osta/oshasoft/index.html].

Web portals were also mentioned as potentially effective ways to deliver information to specific stakeholder groups. However, participants noted that EPA’s Web portals that target particular user groups (e.g., businesses) do not provide sufficient guidance or easy access to relevant information, and are not easy to navigate. Often, portals contain a “hodgepodge” of information, only some of which is relevant, making it difficult for users to find what they are looking for. One participant noted that EPA’s Risk Assessment Portal contains some very simplistic summaries of risk assessment (e.g., at the 8th grade level) and then catapults into PhD level discussions of very specific aspects of risk assessment. It is not calibrated for differing audiences trying to understand the topic but appears, instead, to be just a repackaging of existing content to create the portal.

To counteract the negative experience some users have with www.epa.gov, participants suggested that EPA employ a “push” strategy to the disseminate environmental information. This would entail active outreach to business stakeholders through information intermediaries, trade associations, chambers of commerce, and targeted newsletters.

Participants noted that EPA is faced with two distinct industry worlds: a few big companies, and “millions” of small businesses. In general, big companies work well with EPA and have good regulatory compliance records. They have entire departments dedicated to environmental compliance. On the other hand, small businesses often have “no idea what’s going on” with regard to applicable environmental regulations, and EPA needs to reach out much more to this group to educate them and assist them in achieving compliance. One participant pointed out that very small businesses are even difficult to reach through associations or chambers of commerce, and that the best way to get in touch with this industry segment is through direct mailings of guidance materials – in paper and electronic formats. Another industry representative added that increased EPA presence at localized conferences would be helpful.

In general, the industry representatives were ambivalent about the use of new technologies, such as podcasts and wikis. One representative pointed out that EPA’s Web-based glossary is out of date and suggested that EPA could use wikis to work collaboratively with the public to update it. Another representative cautioned that there is a growing trend in high schools and colleges to disallow footnoting to wikis in papers because of trust and security concerns.

Several representatives indicated that webcasts are a good tool to disseminate information, and noted that they are particularly interested in Stephen Johnson’s webcast. Webcasts are easier to digest than reading, and manage to captivate people’s interest more than yet another fact sheet, e-mail, or memorandum. They tend to be concise and provide a quick summary of the top level item related to a particular topic. One representative said that he would listen to podcasts, if they are short enough so that he could hear the entire piece on his Metro ride home.

Another respondent added that it would be extremely helpful for EPA to customize its listservs [https://lists.epa.gov/read/all_forums] so that users can tailor the information they wish to receive to their specific needs. Current listservs are overly generalized and mailings take too long to digest. In addition, the mailings should be short enough so that they are easily readable on a BlackBerry®. One respondent pointed out that the U.S. Department of the Treasury [http://www.ustreas.gov] has a good listserve for small businesses [eNews for Small Businesses, http://www.irs.gov/businesses/small/content/0,,id = 154826,00.html].

Additional Comments

When given the opportunity to provide additional suggestions, participants suggested that EPA include a list of the top ten things the Agency hears during the listening session and outline how it intends to respond to these concerns. The participants stressed that the final information strategy should be very clear about implementation and explicit about the allocation of resources to specific tasks, timelines for new procedures, and changes to staff job descriptions.

Participant Summary
Group I: Industry

The information in the following table, compiled from participant sign-in sheets, summarizes key data about the participants. As shown, the six industry participants work at large companies and national associations representing U.S. businesses. They include policy advisors, data analysts, and environmental program managers.

Summary of Industry Representatives


Job Title

Job Description

American Petroleum Institute (API)

Senior Policy Advisor

Represents oil and gas industry’s position on domestic and international environmental, corporate social responsibility (CSR), revenue transparency, trade, and emerging issues.

Edison Electric Institute

Director, Environmental Policy

Not provided.

IPC – Association Connecting Electronics Industries

Director of Government Relations and Environmental Policy

Monitors regulatory and legislative issues in US and abroad. Advocates for members.

Lockheed Martin Corporation

Environmental Program Manager

Works on corporate environmental compliance;
Lead for “Go Green” waste and water reduction program.

National Federation of Independent Business (NFIB)

Senior Data Analyst

Analyzes economic impact of public policy/legislation. Conducts database management and research.

U.S. Chamber of Commerce

Vice President, Environment, Technology, and Regulatory Affairs

Manages policy division on rulemaking and legislative issues


Types of Environmental Information

The industry participants provided the following information about the types of environmental information they use:


Uses of Environmental Information

The industry representatives indicated that they use environmental information in the following ways:


  1. Participants did not seem to be familiar with EPA’s Regulatory Information by Business Sector portal: http://www.epa.gov/lawsregs/bizsector/index.html

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