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P2 Awards, 1996 - Genencor International Inc.

Ms. Alice J. Caddow
Vice President, Regulatory
and Environmental Affairs
Genencor International, Inc.
925 Page Mill Rd.
Palo Alto, CA 94304-1013

Re: Recognition of Innovation in Pollution Prevention-- PMN 94-1558 and PMN 95-419

Dear Ms. Caddow:

EPA's Office of Pollution Prevention and Toxics (OPPT) would like to recognize Genencor International, Inc., for an important innovation in pollution prevention (P2). This innovation involves the use of intergeneric microorganisms to synthesize indigo dye, as described in the biotechnology premanufacture notices (PMNs) 94-1558 and 95-419 submitted to EPA pursuant to Section 5 of the Toxic Substances Control Act (TSCA). EPA's New Chemicals P2 Recognition Program congratulates you for this technological innovation.

The manufacture of indigo using genetically altered Escherichia coli K-12 strains represents a significant innovation in the manufacture of indigo, which is traditionally produced through conventional industrial chemistry. OPPT has promoted the use of Green Chemistry (i.e., safer alternative synthetic pathways for manufacturing commercial chemicals) as part of its pollution prevention program because such innovations often lead to reduction in the potential sources of pollution (source reduction). EPA considers Genencor's new process for manufacturing indigo dye to be worthy of recognition because, if adopted commercially, it would avoid the use of hazardous chemicals and the generation of hazardous chemical byproducts that occurs in the existing process. By converting to the microbial synthesis of indigo, which uses glucose and other microbial nutrients as its feedstocks, the commonly used hazardous chemical feedstocks (aniline, formaldehyde, and hydrocyanic acid) can be avoided. These materials are listed on the EPCRA 313 Toxic Release Inventory. Eliminating the use of such hazardous chemical feedstocks via replacement with a more environmentally friendly process would mean that risks, exposures, releases, recycling, and reporting on these chemicals would be reduced.

OPPT has instituted the P2 Recognition Program as a means to encourage innovation and further pollution prevention. In addition to formal notice by letter, EPA is considering publicly listing P2 Recognition recipients on the Internet and perhaps in other media as well. The Agency may also publish articles describing the pollution prevention benefits of specific chemicals which are the subject of a PMN. As always, confidential business information claims will limit our ability to communicate about these new chemicals and to announce, describe and promote these P2 innovations. The Agency welcomes your ideas and comments on how best to recognize and spread the word about your and other noteworthy P2 accomplishments.

Issuance of a P2 Recognition Letter, as described above, is contingent on submission of a Notice of Commencement of manufacture(NOC). EPA recognizes that innovative products and processes may sometimes face obstacles in the marketplace which may delay or hinder commercial development. In the interim, the Agency will issue letters recognizing the development of innovative technologies which promise significant environmental benefits, in the hopes of encouraging companies to pursue commercialization of innovative products and processes. The Agency has not as yet received an NOC for either of Genencor's PMN microorganisms. Given the important benefits to be derived from these microorganisms we hope to see NOCs submitted for these PMN microorganisms in the near future.

When you have new information or if you have any questions regarding the P2 Recognition Program, please contact David Giamporcaro (202-260-6362). You can reach him by fax at 202-260-0118, or write to him at Mail Code 7405. Mr. Giamporcaro may also be reached by E-mail at giamporcaro.david@epamail.epa.gov. Also, EPA's Office of Pollution Prevention and Toxics runs the President's Green Chemistry Challenge Awards program; your PMN microorganisms may be good candidates for this award. (For information on how to apply, please contact Tracy Williamson at 202-260-3960.)

Again, congratulations on your P2 innovation. EPA looks forward to the receipt of NOCs for these products which will allow the Agency to officially recognize Genencor's P2 achievements. The Agency wishes you continued success with future innovations.

William H. Sanders III, Dr. P.H., P.E.
Director, Office of Pollution Prevention and Toxics

cc: W. Thomas Mitchell, President and CEO
     Genencor International


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