Note: This information is provided for reference purposes only. Although the information provided here was accurate and current when first created, it is now outdated.

CHEMICALS-IN-PROGRESS BULLETIN
FALL 1995/WINTER 1996 (EPA-745-N-95-002)
EPA/OFFICE OF POLLUTION PREVENTION & TOXICS

Mike McDonell, Co-Editor
Maureen Eichelberger, Co-Editor

[EDITOR'S NOTE: Due to budget constraints, this issue of CIPB will only be
available on the Internet and EPA's Electronic Bulletin Board. There will not
be an external mailing of this issue.]

TABLE OF CONTENTS

Government Shutdown Delays TRI Reporting.............................Page 1
Lead Update..........................................................Page 1
Biotechnology Workshop Scheduled for Late March......................Page 2
EPA Explores Chemical Use Expansion for TRI..........................Page 2
Environmentally Preferable Products and Services.....................Page 3
Home Depot Offers Lead Hazard Guidelines.............................Page 3
OPPT Issues Sweeping Revisions to New Chemicals Regulations..........Page 4
Compliance with Reporting Requirements of the Revised PMN Rule.......Page 5
EPA Launches Key Identifiers Project.................................Page 6
TRI Conference a Resounding Success........................... ......Page 8
EPA's Existing Chemicals Program: Testing & Risk Management..........Page 8

==============================================================================

Government Shutdown Delays TRI Reporting

The recent government shutdown has delayed by one month the U.S.
Environmental Protection Agencyþs ability to collect community right-to-know
information about local toxic releases of chemicals from manufacturing
facilities around the nation.

Under the Emergency Planning and Right-to-Know Act, manufacturers are
required to provide EPA with data on local releases of toxic chemicals by July
1 each year. Due to delays in preparing this yearþs reporting forms, EPA has
used its enforcement authority under the Act to postpone the reporting deadline
to August 1, 1996. EPA will provide reporting forms to manufacturers by mid-
April this year, rather than by mid-March.

Lead Update

Following is an update on EPA's Lead-Based Paint Program activities, as
reported in the Summer issue:

* Training, Accreditation and Certification for Lead-based Paint
Activities (402/404) - Comments received are currently being
reviewed and final promulgation is anticipated for Winter 1996.
* Lead Hazard Brochure (406(a)) - The final brochure is available in
English and Spanish from the National Lead Information Center
(1-800-424-LEAD), or in bulk quantity from the Government Printing
Office (GPO).
* Renovation Information Rule (406(b)) - Expected to be final by Winter
1996.
* Disclosure of Lead Hazards During Real Estate Transactions (1018)
- Final promulgation is anticipated for Winter 1996.

Biotechnology Workshop Scheduled for Late March

A workshop on Environmental Fate and Effects Test Methods for
Microorganisms is planned for March 25-26, 1996 in the Washington, DC area.
The workshop is jointly sponsored by U. S. EPA's Office of Pollution Prevention
and Toxics and by Agriculture and Ag-Food Canada. Specific topics of
discussion include (1) test methods for assessment of microbial pathogenicity,
(2) test methods for assessment of the toxicity of chemical metabolites
generated by microbial degradation of hazardous wastes, (3) test methods for
assessment of broader ecological effects of microorganisms, and (4) test
methods and models for subsurface fate of microorganisms used in
bioremediation. For general information about attending the workshop contact
Ms. Marsha Gardner, SRA Technologies, Inc., phone 703-205-8547, FAX x6260.

EPA Explores Chemical Use Expansion for TRI, by Mike McDonell

On August 8, 1995, in the face of Congressional efforts to scale back the
Community-Right-to-Know program, President Clinton issued the Federal
Acquisition and Community-Right-to-Know Executive Order requiring all
government contractors to adhere to the provisions of the Emergency Planning
and Community Right to Know Act of 1986 (EPCRA). In a memorandum to the
Administrator, the President also directed EPA to develop and implement "an
expedited, open and transparent process for consideration of reporting under
EPCRA on information on the use of toxic materials at facilities, including
information on mass balance, materials accounting, or other chemical use
data..." The memorandum went on to direct EPA to submit a report on the
progress of this effort.

On October 2, 1995, EPA submitted a report to the President entitled
"Expansion of Community Right-to-Know Reporting to Include Chemical Use Data:
Phase III of the Toxics Release Inventory (TRI)." In the report, the Agency
expressed a strong commitment to expanding the Community-Right-to-Know program
to include chemical use information. The report also pledged a process that
includes full opportunities for public comment, pilot studies and public
meetings.

EPA previously addressed the issue of collecting chemical use information
via TRI reporting in an issues paper dated September 2, 1994. The paper was the
focal point for a public meeting held September 28, 1994. Following that
meeting, EPA reviewed the comments and evaluated the issues raised. EPA
subsequently made available a second issues paper on October 4, 1995 which
reported back to stakeholders, laid out the agency's position on materials
accounting, and focused attention on important unresolved issues. The paper
also served as the focus for a public meeting held October 18 and 19, 1995.

At the public meeting, stakeholders heard the Agency's views on the issues
reiterated and expanded upon by a variety of agency officials including
Assistant Administrator Lynn R. Goldman and the Director of the Office of
Pollution Prevention and Toxics, William Sanders. Attendees were also given the
opportunity to express their views on collecting chemical use information and
related issues. EPA committed itself to notifying the public by mid-January
1996 on the next steps that the agency will take as the project develops.

For copies of the Presidential Report, Issues Paper #1 and #2, call the
EPCRA Hotline at 1-800-535-0202.

Environmentally Preferable Products and Services, by Julie Shannon

EPA's proposed guidance on environmentally preferable products and
services was signed by Administrator Browner on September 25 and published in
the Federal Register on September 29 [FR #60FR 50722].

The proposed guidance responds to President Clintonþs Executive Order
12873 Federal Acquisition, Recycling and Waste Prevention which seeks to use
the purchasing power of the Federal government to advance environmental goals.
Section 503 of this Executive Order requires EPA to "issue guidance that
recommends principles that Executive agencies should use in making
determinations for the preference and purchase of environmentally preferable
products."

The Executive Order defines "environmentally preferable" as "products or
services that have a lesser or reduced effect on human health and the
environment when compared with competing products or services that serve the
same purpose". The proposed guidance is the first step in OPPT's approach to
translating this into a form practical to federal purchasers.

EPA's proposed guidance serves as a broad framework within which Federal
agencies can initiate efforts to make their purchasing decisions more
environmentally preferable. It lays out seven principles that are intended to
guide Federal purchasers as they consider environmental preferability in their
acquisition decisions. These guiding principles include:

o POLLUTION PREVENTION: Consideration of environmental preferability
should begin early in the acquisition process and be rooted in the
ethic of pollution prevention;
o MULTIPLE ATTRIBUTES: A product or service's environmental
preferability is a function of multiple attributes;
o LIFE-CYCLE CONSIDERATIONS: Environmental preferability should
reflect life-cycle considerations of products and services to the
extent feasible;
o LOCAL CONDITIONS: Environmental preferability should be tailored to
local conditions where appropriate.

The general guidance also lays out the second part of EPA's implementation
plans: to work in cooperation with Executive agencies on voluntary pilot
projects, to apply these principles to specific acquisitions and develop
guidance for certain product categories. Product categories could include
services, facilities and/or systems in addition to common supplies purchased by
the federal government. Currently underway are pilot projects on cleaners,
computers, and buildings. While the general guidance is aimed at public and
private policy-makers, the product guidances will be more detailed, practical
and þuser friendlyþ for use by procurement and contracting officers.
Interested parties were encouraged to provide input to EPA on the proposed
guidance. A public meeting was held October 26th at the Crystal City Hyatt
Regency in Arlington, VA. Copies of the proposed guidance are available
through the Pollution Prevention Information Clearinghouse (202-260-2736). For
additional information contact Eun-Sook Goidel at 202-260-3296.

Home Depot Offers Lead Hazard Guidelines, by Darlene Watford

Home Depot, the national hardware chain store, distributed flyers containing
information from one of OPPT's lead pamphlets. Last year, OPPT prepared
guidelines about the potential lead hazards of conducting home renovations.
The guidelines were included in a pamphlet entitled "Reducing Lead Hazards When
Remodeling Your Home"(EPA 747-R-94-002, April 1994). They list the basic
steps that must be taken to reduce exposure to lead while conducting renovation
and remodeling activities and are intended for contractors, homeowners, paint
and hardware stores, trade groups, and State and local government agencies.

Home Depot reformatted the information onto large double-sided paper. The
store sent copies of the flyers to all Home Depot locations to distribute to
customers. The flyers may be obtained from the paint centers in any Home
Depot store. We are extremely pleased that we could establish this
cooperative effort with the hardware industry. We have been trying to convince
national and regional hardware chain stores to reproduce and distribute our
document in their stores. Home Depot is the first national hardware store
that has agreed to provide this information to their customers as a public
service. (The original EPA pamphlet may be obtained by calling the National
Lead Information Center Clearinghouse at 1-800-424-LEAD).

OPPT Issues Sweeping Revisions to the New Chemicals Regulations, by Mary
Cushmac

On March 29, 1995, OPPT published sweeping revisions to the regulations
affecting the manufacture of new chemical substances. These final rules,
intended to streamline the New Chemicals Program and reduce the number of
premanufacture notices (PMNs) industry must submit for new chemical substances,
took effect on May 30, 1995. OPPT expects that the amendments will achieve a
more efficient regulatory process, implement cost-savings for EPA and
submitters, and allow submitters greater flexibility in manufacturing certain
new chemical substances. The rules encourage the manufacture of safer
chemicals and substances produced with low exposure and low release and allow
the Agency to shift its limited resources from the review of low-risk
substances to those that may present a higher risk. Further, the rule fosters
international accord since Environment Canada has adopted the Agency's low-risk
criteria for polymers in their new chemicals regulations and the Organization
for Economic Cooperation and Development has expressed strong interest in EPA's
criteria for low-risk polymers.

Although it is too early to determine the overall impact of these
amendments, industry appears to be submitting an increasing number of low
volume exemption applications under the expanded production volume limit of
10,000 kg/year. EPA estimates that about 27 percent of PMNs fall within this
production volume range and could qualify for the shortened review period of 30
days instead of the full 90 day PMN review. Further, EPA recently granted its
first exemption under the newly introduced Low Exposure/Low Release Exemption
(LOREX) and is in the process of reviewing a second application. Similarly,
EPA expects significant use of the newly expanded polymer exemption, since
polymers that meet the low-risk exemption criteria are no longer subject to PMN
review. EPA estimates that about 34 percent of PMNs could qualify for the
polymer exemption. The Agency will receive specific information on the number
of polymers being manufactured under this exemption in the January 1996
reporting cycle.

While industry has taken advantage of the flexibility offered by the
expanded exemptions, EPA has noted that a significant number of PMN submitters
have not complied with certain revised PMN regulations. In particular, the
failure to provide correct Chemical Abstracts nomenclature in PMNs and other
TSCA section 5 notices has resulted in "incomplete" submissions and delay in
initiating the PMN review process. For more information on this issue, please
see the accompanying article.

Since 1979, EPA has reviewed over 27,000 Toxic Substance Control Act
(TSCA) Section 5 notices for new chemical substances and has taken regulatory
action on approximately 10% of these substances. Over the years, the New
Chemicals Program has implemented a number of initiatives to enable the Agency
to review a growing number of new substances. EPA used the knowledge and
experience in the New Chemicals Program to develop the final amendments to
promote more efficient regulatory oversight of new chemical substances without
compromising protection to human health or the environment.

OPPT held three public meetings to discuss the final rules and prepared
numerous written materials to explain the changes in the PMN regulations and
exemptions. Copies of these materials may be obtained by contacting the TSCA
HOTLINE at 202-554-1404 (phone) or 202-554-5603 (fax).

==============================================================================
Revised New Chemicals Program Brochure Now Available: The updated version of
the New Chemicals Program Brochure (document #EPA-743-95-001) is available by
contacting the TSCA Hotline at 202-554-1404.
==============================================================================

Compliance with Reporting Requirements of the Revised PMN Rule, by Greg Fritz

In a continuing effort to improve review and evaluation of new chemicals,
EPA promulgated a rule on March 29, 1995 that revised the Premanufacture
Notification (PMN) Regulations of 1983. The revised PMN rule became effective
on May 30, 1995. Since then, a significant number of PMN submitters have
failed to comply fully with some of the reporting requirements of the revised
rule, particularly in the area of chemical identity and nomenclature. This
article discusses some of the problems EPA has encountered since May 30, 1995.

Upon receipt of a PMN, EPA chemists inspect the information provided by
the submitter to ensure that the required technical information has been
submitted correctly. This "prescreening" for completeness occurs before the 90
day review "clock" starts. A PMN that is found to be complete enters the
review period with day 1 assigned to coincide with the date of receipt. During
either the prescreening stage or the subsequent first thirty (30) days of the
review process (40 CFR 720.65(b)), EPA may determine that required information
is either missing or wrong. When this determination is made, EPA declares the
PMN incomplete and the submitter is notified that a new PMN must be submitted
in its entirety, with a new day 1 to be assigned when the resubmitted
information is determined to be complete.

Chemical identity information is critical to the PMN review and
deficiencies in this area will result in the PMN being declared incomplete.
The chemical name provided must accurately reflect the known composition and
reported chemical identity information of the PMN substance. The revised rule
requires that each PMN substance be identified by a correct Chemical Abstracts
(CA) Index name or CA Preferred name that is consistent with the application of
the Ninth Collective Index (9CI) of CA nomenclature rules and conventions. In
addition, the name must be consistent with TSCA Inventory listings for similar
substances.

The submitter must provide this name using one of two methods. Method 1
requires the submitter to specifically use the Chemical Abstracts Service (CAS)
Inventory Expert Service (IES), as opposed to the CAS Registry Service, some
other service provided by CAS, or utilizing some other source of information.
CAS IES will provide the correct chemical name that will be used in the PMN for
Inventory purposes. EPA has observed that most problems with nomenclature have
occurred when submitters used Method 2 (providing a chemical name themselves or
using a source other than the CAS IES). If a submitter uses Method 2 and fails
to provide a chemical name that adheres to the CA nomenclature rules and
conventions proscribed in its 9CI or that is inconsistent with how similar
substances are identified for TSCA purposes, the chemical name is considered
incorrect and EPA declares the PMN incomplete.

The second error commonly found by EPA is inconsistent chemical identity
information. This occurs when a submitter provides some information in the PMN
that describes the reported chemical as one substance while other information
in the notice appears to describe a different substance. For example, the
specific chemical name may not fully match the structural diagram, and EPA may
not be sure which information correctly represents the chemical that is the
subject of the PMN.

The following items must be consistent with only one chemical identity; if
any are inconsistent, EPA declares the PMN incomplete. These items include but
are not limited to chemical name, CAS Registry Number, chemical structural
diagram, molecular formula, reactants used, impurities present, and
manufacturing process description.

EPA also declares a PMN incomplete for failure to identify specifically
and correctly all reactants used to manufacture complex substances or polymers.
Although the PMN rule amendments do not require CA Names for each of these
chemicals, a correct chemical name and CAS Registry Number (when available) are
required for each reactant. Trade names and generic or non-specific names
(i.e., alkylphenol for 4-tert-butylphenol) are never permitted. In some
instances, the manufacturer may not know the specific chemical identity of a
proprietary reactant it purchases and uses to make the PMN substance and hence
the full identity of the resulting PMN substance is unknown. When this occurs,
the PMN submitter must get a letter of support sent directly to the EPA from
the supplier, who must accurately describe the identity of the proprietary
reactant. Even when the reactant is the subject of a previous PMN, a correct
chemical name must be provided in the PMN or in a letter of support.

Finally, when a PMN does not contain a chemical structure to the extent
that one is known to exist or is reasonably ascertainable by the submitter, EPA
declares it incomplete. This often occurs for polymeric or complex substances
for which no specific structure accurately describes the entire PMN substance.
There are other instances in which the PMN substance cannot be easily
represented structurally or for which structural information is truly unknown.
For these cases, the PMN submitter must provide the most likely representative
or partial structure(s) possible.

As stated above, these are a few of the more common errors that can cause
EPA to declare a premanufacture notice incomplete. In most cases, these errors
can be corrected or avoided altogether by meticulous preparation of PMNs.
Further information regarding chemical identity for PMN reporting can be found
in the EPA document entitled EPA Guidance Concerning Incomplete Chemical
Identity Information in Section 5 Notices. This three page document is
available by contacting the TSCA Hotline at (202) 554-1404.

EPA Launches Key Identifiers Project, by Diane Sheridan

The Key Identifiers Project is an Agency-wide initiative being lead by
the OPPT in cooperation with several of EPA's major program offices. The
purpose of the project is to streamline the collection of "place-based"
information for facilities subject to Federal reporting requirements for
environmental data. In August 1994 a report by the National Advisory Council
on Environmental Policy and Technology (NACEPT) recommended that the EPA move
toward comprehensive information resources management. In response to the
NACEPT report, the Agency has launched a number of different initiatives
designed to establish an integrated information infrastructure for supporting
comprehensive approaches to environmental protection. One of these initiatives
is known as the Key Identifiers Project.

The Problem
Currently, environmental data is collected by EPA and its State partners
under the auspices of a number of different regulatory authorities. Data
collected has a media specific focus and is managed separately by EPA and State
program offices. In many cases these data collections are generated on or
about the same location or facility. So companies or others subject to the
requirements must continue to submit similar data about their location multiple
times to the EPA or the State.

How will the Key Identifiers Project work?
The Key Identifiers Project will improve the Agencyþs information
resources management and lay the foundation for consolidation of reporting
requirements across EPA's media programs. The EPA plans to propose changes
from its single media information collection of place-based information
through development and promulgation of a rulemaking. The Rule will establish
a single, authoritative set of facility identification information for use by
the EPA, the States, and the public. This approach should over time provide a
degree of reporting burden reduction. It will help the regulated community
know what EPA or State data systems contain their data that they have invested
so much time in developing and submitting. Also, establishing a standardized
format for submission of facility information will lead to more efficient use
of the reported data by EPA and its State partners, and the public. At the
same time the rule will amend a number of existing regulations, removing
specific facility reporting elements.

What is the status of the Key Identifiers Rulemaking?
An EPA regulatory workgroup composed of representatives from all major
program offices has been meeting since March of this year. The workgroup, in
pursuing the first step toward establishing an integrated information
structure, has begun to identify common data elements containing facility
identifying information or place-based information. Place-based information
specifically includes elements such as the name, location, and point of contact
for a facility, industrial classification, and corporate affiliation. These
common place-based data elements will provide the framework for linking
facility environmental data across many media databases. The information
gathered under the Key Identifiers Rule, will be entered into a central
facility data base.

What are the major issues associated with this Rulemaking?
In addition to identifying the data elements for the new central facility
data file, the workgroup has been struggling with a number of major issues.
The first is deciding what criteria should be used for determining the
environmental data collections that should be covered under the Key Identifiers
Rule. For example, should the Rule cover only those collections that: 1)
relate to facilities that are subject to environmental reporting; 2) cover
facilities that are not mobile, for example mobil source requirements under the
Clean Air Act would be considered outside the scope of this rule; or 3)
require periodic reporting or one-time submissions with periodic follow-up
reporting (for example one-time notifications, surveys, and incident reports
would also be considered outside the scope).

Secondly, once a facility has determined that its reporting requirements
are included in this Rule what criteria should be used for determining how a
facility should be defined. The issue is whether the term facility should be
defined as follows: 1) comprehensively to apply to one geographic location
under the ownership or control of the same person; or 2) if the facility
should define its own boundaries; or 3) the facilities should use the
existing definitions outlined in the regulations under which they currently
report. The main objective in defining the facility consistently is to ensure
cross-media consistency so that this same record can be the foundation of
facility records in multiple databases.

Thirdly, once the initial data collection has been implemented, users of
the Key Identifiers data bases must be confident of its ongoing integrity. In
order to provide an authoritative registry of identifying information, the EPA
must establish a consistent schedule for supplying updates to their Key
Identifiers submissions. Some of the options under consideration include the
following: 1) require a yearly update; 2) require an update only when
changes occur; 3) require an update as changes occur but provide periodic
verification; or 4) update through existing reporting mechanisms.

Lastly, since states conduct environmental programs that parallel Federal
programs, EPA and the states must develop a mutually agreeable model for how
data will flow through the States to the Key Identifiers facility registry from
all federally regulated facilities. The EPA is currently working on developing
a prototype interactive system that will provide options to promote maximum
flexibility for those States that currently collect facility data.

Next Steps
The Key Identifiers rule is expected to be proposed by the end of calendar
year 1995 and promulgated in final by the fall of 1996. Questions regarding
the Key Identifiers Project may be addressed to Diane Sheridan on (202)
260-3435.

TRI Conference a Resounding Success, by Jan Erickson

OPPT, in conjunction with the New England Waste Management
Officials (NEWMOA), sponsored the fourth TRI Data Use Conference in
Boston last Winter. The event brought together public interest
groups, researchers, labor, industry, citizens, and federal, state,
and local officials that use toxics information. This yearþs
conference set a record for the number of attendees, reflecting not
only the diversity of TRI users, but the commitment to this program
felt by a growing number of citizens and groups. Sessions were
organized into three tracks: using TRI for pollution prevention,
partnerships between TRI stakeholders, and innovative ways of using
the data. In over sixty presentations (as well as poster sessions,
computer demonstrations, and informal gatherings), participants shared
their experiences. They described state programs, grass roots
efforts, industry initiatives, research projects, and more. In
addition to providing a forum for members of the TRI community to
learn from each other, this conference addresses an even more vital
goal: fostering trust and cooperation with our TRI partners.

Papers presented at the TRI Data Use Conference as well as
summaries of other conference events are contained in the Conference
Proceedings, available from the U.S. Government Printing Office for
$14.00 (stock no. 055-000-00510-9).

EPA's Existing Chemicals Program: Testing & Risk Management, by
Deborah Williams,

The U.S. Environmental Protection Agency's (EPA) Existing
Chemicals Program gathers hazard and exposure data, screens for
hazards/risks, identifies testing needs and establishes testing
requirements. The Program also evaluates and develops strategies for
preventing pollution and reducing the risks associated with chemicals
currently in production or use. OPPT's risk management and pollution
prevention initiatives can be either regulatory or non-regulatory;
all, however, are aimed at reducing or eliminating the likelihood of
harm to health and the environment.

Risk management activities in the Existing Chemicals Program are
divided into RM1, RM2 and Post RM2 stages. Risk Management 1 (RM1)
is the first component and takes about six months. This step is
designed to screen and select chemicals that appear to be of greatest
concern to human health and the environment and takes about six
months. Risk Management 2 (RM2) is the next step, and takes 12 to 24
months. In RM2, chemicals identified in RM1 are investigated and
analyzed, and options are framed for reducing or eliminating the risks
they pose. Post RM2, which can range between 3 months and 2 years,
consists of the implementation of one or more of the risk reduction
options identified in RM2.

While the Existing Chemicals Program is located in the Chemical
Control Division of the Office of Pollution Prevention and Toxics
(OPPT), contributions to the Program come from all parts of OPPT.
This collaborative approach ensures well-balanced management of the
wide array of cases pursued. The Existing Chemicals Program draws
most of its cases from about 15,000 chemicals which are nonpolymers
produced at less than 10,000 pounds per year. The remaining 55,000 of
the 70,000 existing chemicals listed on the TSCA Chemical Inventory
are not currently on the Agenda for screening or investigation by the
Existing Chemicals Program. These chemicals are either produced at
less than 10,000 pounds per year, if at all, or are polymers, which
because of their chemical make-up, are not considered likely to
present a significant risk to health or the environment.

The Program is very productive. Over 1900 chemicals have been
screened in RM1 since fiscal year 1993. With regard to chemical
testing activities since FY93, more than 600 chemicals have been
identified on the Master Testing List (MTL) and more than half of
those are currently undergoing testing. Testing action development is
underway on almost all other chemicals on the List. Testing programs
have been completed on more than 50 chemicals since fiscal year 1993
and the results forwarded to RM1 for review & disposition since FY93.
Through accelerated projects, strategic use of contracting and in-
house resources, and the cooperation of stakeholders, EPA has been
able to reach this level of productivity in the Existing Chemicals
Program on a small, and continually decreasing budget.

The Existing Chemicals Program has pursued a variety of
approaches to get results. Regardless of the approach used, the
Program has produced a number of successes that have made, and are
making, a difference in people's lives. The Program has used three
case types (chemical, use, facility) and the following nine approaches
in recent years to carry out its work on single chemicals, use
clusters and facility specific cases:

* Voluntary Actions include negotiated agreements for testing,
hazard communication, product stewardship, safer work practices,
or termination of the sale or use of a chemical or product.
Voluntary actions are comparable in effectiveness to regulation,
and often can be accomplished more quickly.

* Government Partnerships involve cooperation among regional,
federal, state, and local governments. EPA is often able to
provide technical and analytical work to support the actions of
its partners.

* Regulation or a Combination of Voluntary Actions and Regulation
is sometimes the best solution.

* Pollution Prevention and Promotion of Safer Substitutes are
emphasized, including removing chemicals of concern from the
marketplace or reducing the emissions of certain chemicals.

* Toxics Release Data from the Toxics Release Inventory (TRI) is
used to target chemicals and facilities of concern.

* Information Dissemination is a valuable tool for obtaining
results -- with sufficient dissemination, the RM2 (Risk
Management) assessment document itself can help groups promote
behavior changes.

* Risk Assessment and Benefit/Cost Analysis provides an objective
look at a concern, allowing an open and informed discussion of
the issue.

* Involvement of Stakeholders early in the process and frequently
throughout helps to ensure their needs are being met. All
projects have stakeholder meetings at the beginning and end of
the RM2 (Risk Management) process.

* Product Stewardship is a principle many industries have committed
to follow. EPA has successfully challenged industry to fulfill
their Product Stewardship and Responsible Care commitments.

There are many ways in which government, industry and other
stakeholders can work together to meet the nationþs environmental
goals. In the past, EPA has relied heavily on regulation to
accomplish these goals; we are now recognizing that more cooperative
methods are often more efficient and effective. Regulation is still a
viable tool and is used when necessary. However, the Existing
Chemicals Program, both Testing and Risk Management, is increasingly
turning to the cooperative and voluntary methods described above as
first approaches to reducing or eliminating the likelihood of harm to
human health and the environment.

The following list summarizes the progress and accomplishments of
the RM2 and Post RM2 projects completed since fiscal year 1993 or
those which are soon expected to be completed. The list indicates the
risk management approach used for each project listed. For further
information on any of these projects, please contact the TSCA Hotline
at (202) 554-1404.

CHEMICAL/BACKGROUND/CONCERN/ACTION/TIMELINE

Acrylonitrile / TRI data show large production and releases of
acrylonitrile / cancer / Industry-initiated pollution prevention
programs -- further action unnecessary / Completed 2/93 #

Aerosol Spray Paints / The Clean Air Act is requiring changes in
aerosol spray paints, and manufacturers may not have good information
on chemical substitutes / cancer, neurotoxicity, reproductive and
developmental concerns, target organ effects / Use cluster analysis to
provide information to manufacturers on safer chemical
substitutes #

Benzidine Dyes / Manufacturing and use concerns / cancer / Voluntary
agreements, Significant New Use Rule (SNUR) #

Carpets / EPA recognized that new carpets may be a significant source
of VOC exposure / exposure to volatile organic compounds (VOCs) /
Carpet Policy Dialogue -- voluntary partnerships, testing / Completed
9/91 #

Cement Labeling: TSCA Sec. 21 Petition / Petition was filed requesting
labeling for cement produced through burning of hazardous waste fuel
(HWF) / cement dermatitis, lung cancer, asthma / EPA found no evidence
HWF increased the health risks of cement, and labeling duplicated OSHA
regs. No action necessary / Completed 7/95 #

Chloranil / Chloranil is an intermediate chemical used in tires,
paints, and dyes; products are contaminated with dioxin / cancer
reproductive effects / Voluntary phaseout through industry
partnership, SNUR to control reintroduction of chemical / Voluntary
agreements signed 5/92; SNUR to be completed #

Chlorinated Paraffins / Used in metalworking fluids to prevent welding
during cutting / toxic to aquatic life, cancer, formation of dioxin
under certain conditions / Partnered with industry to perform a survey
of releases -- determined that risks were overstated. Listed on TRI /
Completed 9/93 #

Chloroethane / TRI data showed large production and releases / cancer
/ Voluntary agreements resulting in relabeling and lowered exposure
limits for workers / Completed 1/93 #

Consumer / Small Shop Paint Stripping Use Cluster / Nearly all
chemicals in paint strippers are dangerous if used improperly. EPA
looked at this Use Cluster to provide useable information to consumers
/ cancer, neurotoxicity, reproductive and developmental concerns,
target organ effects including liver and cardiotoxicity /
Voluntary partnership to improve customer information / Technical
assessment document expected 12/95 #

Cultural Uses of Metallic Mercury / Some cultures sprinkle mercury in
homes or burn it for luck or spiritual protection / neurotoxicity /
Risk communication and public education through partnership /
Completed 9/94 #

1,2 Dichloroethane (EDC) / EDC is used to make PVC and chlorinated
solvents. TRI data show increased emissions / cancer / Only one
facility posed a concern -- permit violation resulted in a fine of >$3
million and pollution prevention steps to virtually eliminate
emissions / Completed 12/93 #

Formaldehyde and Urea-Formaldehyde Resins In Pressed Wood / Indoor
air concern from pressed wood building materials / cancer, eye, nose,
and throat irritation / Voluntary agreement with the National
Particleboard Association to study exposure / Agreement made 1/94;
study expected to be completed end of 1995 #

Glycol Ethers / Used in the semiconductor manufacturing process /
miscarriage, spontaneous abortion, and impaired fertility in women /
Government industry partnership resulted in a voluntary agreement by
semiconductor mfgr. to phase out chemicals and reduce exposures;
raised risk concerns about potential substitutes /
Completed 9/93 #

GSA Cleaners / The General Services Administration (GSA) needed
better information to purchase and use environmentally preferable
cleaning products / health and welfare of workers, effects on
environment during use and disposal / Partnership with GSA to pursue
P2 and encourage vendors to supply environmental information; will
create guidance to help federal consumers discriminate among products
#

Hydrazine / Significant releases reported in TRI / cancer toxic to
aquatic life/Voluntary pollution prevention efforts / Completed 12/93
#

Land Application of Pulp and Paper Mill Sludge / sludge is
contaminated with chlorinated dioxins and furans are formed during
bleaching / cancer, reproductive and other effects in humans,
reproductive effects in wildlife / Voluntary agreement to limit land
application of dioxin contaminated sludge / Completed 4/94 #

Lead In Non-Residential Paint / Lead pigments are used in paint for
bridges and other steel structures, and for pavement markings /
spontaneous abortions, sterility, nervous system effects, kidney
disease and damage, increased blood pressure, anemia / No action was
taken as the risks were being adequately managed through RCRA, TSCA,
and OSHA / Completed 1/94 #

Lead in Non-Plumbing Solder / This grew out of a regulatory
investigation of lead solder in drinking water pipes / spontaneous
abortions and sterility, nervous system effects, kidney disease and
damage, increased blood pressure, anemia / Industry provided outreach,
new repair techniques, and reduced use to address worker exposure.
Exposure to stained glass workers was referred to OSHA and the CPSC /
Completed 1/93 #

2-Nitropropane (2-NP) / Potentially high occupational exposures in
manufacturing, solvent use, and the printing industry / cancer, acute
liver effects / Case was informally referred to OSHA; letters were
sent to 2-NP manufacturers and worker unions / Completed 7/93 #

N-Methyl Pyrrolidone (NMP) In Paint Strippers / Consumer Product
Safety Commission, EPA, chemical manufacturers and paint stripping
formulators partnered to assess risks / Animal studies showed
reproductive and developmental effects, including impaired fertility /
Government partnership to assess risks: producers began a voluntary
program to test safety measures and educate consumers, and signed an
enforceable consent agreement for additional testing / Completed 10/93
#

Nitrosamines / Rubber industry workers may be exposed at high levels /
cancer / Government partnership to encourage voluntary risk
reduction

Nitrites in Metal Working Fluids / Nitrites in metal working fluids
can form nitrosamines / cancer / Voluntary elimination of the use of
nitrites in metalworking fluids; SNUR to prevent future risks /
Completed 5/93 #

Octabromodiphenyl-Oxide (OBDMPO)/ Decabromodiphenyl-Oxide (DBDPO) /
OBDMPO and DBDPO may be contaminated by dioxin / cancer, developmental
and reproductive effects / Partnership with industry to implement
voluntary product stewardship to lower inhalation and dermal exposures
#

Phosphoric Acid Production Waste / Phosphoric Acid production
generates large amounts of wastewater and phosphogypsum waste /
environmental concerns, health risk from radon and gamma radiation /
Partnership to identify a pollution prevention solution. No solution
was found, case referred to EPAþs Office of Solid Waste / Completed
4/94 #

Refractory Ceramics Fibers (RCF) / RCFs, man-made fibrous materials
used as insulation, have properties similar to asbestos / animal
carcinogen / Voluntary product stewardship program to reduce worker
exposure, and voluntary testing; SNUR / Completed 5/93 #

Solvents / Industries are substituting aqueous cleaners for
halogenated solvents for metal cleaning and degreasing, with little
information on the environmental consequences / environmental concerns
/ Provided industry information on halogenated solvent regulations,
environmental effects, and toxicity information / Initial outreach
completed #

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