Voluntary Priority and Toxic Chemical Reduction – US EPA

Priority and Toxic Chemical Reduction | Resource Conservation Challenge | US EPA

Priority and toxic chemicals make up a fairly limited volume, yet potentially hazardous portion of the nation’s waste stream. We are working to eliminate or reduce priority chemicals and other chemicals of national concern from commercial products, waste streams, and industrial releases through pollution prevention, waste minimization, and recycling/reuse.The 31 priority chemicals are federal priorities because they are persistent, bioaccumulative, and highly toxic. We’re focusing on reducing priority and toxic chemicals to better protect human health and the environment.

By substituting or eliminating certain chemicals in their manufacturing processes, companies produce less waste and thus lower their waste disposal costs. Our goal is to substantially reduce the volume and toxicity of priority chemicals in waste by asking companies to voluntarily:

  • Substitute safer alternatives when they can;
  • Minimize the amount of priority chemicals they use, if they can’t substitute for them;
  • Maximize their recycling efforts;
  • Practice cradle-to-cradle chemical management; and
  • Design products to minimize exposure to, and release of, priority chemicals during manufacturing and use.

Sounds good, and Worldchanging has more:

But nowhere near the progress some companies are making on their own in cleaning up toxic emissions — not simply to be good guys, but to reduce their costs, liabilities, and exposure to activist and shareholder pressures. And, in some cases, to meet their customers’ growing demands for less-toxic or nontoxic alternatives to business as usual.

Read the whole post, which sounds ambivalent about the scheme. The idea is Environmental Good Sense 101, use less, or none at all, practice cradle to grave economics and minimize exposure. Simple stuff, huh. The biggest problem, however, is that by setting limits on a voluntary basis, you always run the risk of setting the bar too low, and then indulging in relentless and pointless self congratulation about how the “market” solved everything, and how rules are so, well, 1970s?

you need a good mix of

  1. Regulation, which sets a minimum, health based bar
  2. Flexibility to the business on how to achieve their targets
  3. Market systems to trade emission credits, etc
  4. Voluntary industry-government initiatives like the one above
  5. Relentless citizen activism that forces governments/business to act
  6. Community outreach and education so consumers can make informed choices
  7. Costing mechanisms that actually reflect free market efficiencies (no stupid subsidies, accurate costing of “externalities”, etc. )

Yeah, this does not fit neatly into the Mano a Mano, you’re with us/you’re against us false dichotomy of choice that seems to beset almost every policy debate (environmental or otherwise). It seems that you never have to do one or the other, but a bit of both, or all of them at the same time.

In the meanwhile, the voluntary program will work, but only in areas in specific instances where it is to a company’s advantage.

BTW, I think that good old fashioned regulation in Europe – See Reach and many many more existing regulations, such as this one for PCBs and Dioxins which I know a little too much about, have a little more to do with American companies reducing POP levels that they care to admit!

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    You breathe in toxic chemicals too.

    Behind a frigging pay wall, as usual! Kelly et al. argue in Science that hydrophobicity, the tendency to favor oil over water (to break it down to the simplest explanation) is not the only factor that explains biomagnification. The underlying theory used to be that compounds that can dissolve in water would swiftly degrade (either chemically or biologically) and not be of any concern to humans. Compounds like dioxins, PCB’s, DDT, etc. accumulated in fat tissue of aquatic animals and these were the compounds that would biomagnify through ingestion (eating!). Kelly et al. uncover another pathway that probably made every scientist go “D’uh”! – Apparently, chemicals animals breathe in can also bioaccumulate if they are not cleared efficiently by the lungs. So, air breathing cows, chickens and pigs can also cause significant bioaccumulation of certain compounds. Which ones? I guess you’ll have to pay to find out more, but this Scientific American article adds some context. Turns out, it is about 10000 chemicals, not all of them known to be harmful, but because they were never suspect, their metabolism is unknown.

    Well, if anything, it will keep the biomonitoring folks busy for a while!

    Chemical Consequences — 317 (5835): 165g — Science

    Global regulators of commercial chemicals apply a scientific paradigm that relates the biomagnification potential of the chemical in food webs to the chemical’s hydrophobicity. However, Kelly et al. (p. 236; see the news story by Kaiser) show that current methods fail to recognize the food web biomagnification potential of certain chemicals. Certain chemicals do not biomagnify in most aquatic food chains, but biomagnify to a high degree in air-breathing animals, including humans, because of low respiratory elimination. Thus, additional criteria for evaluating biomagnification and toxicity in chemicals that biomagnify are required.

  • EPA Accused of Flouting Supreme Court – washingtonpost.com

    You may remember from a few weeks back when the supremes in a very rare unanimous decision ruled that the Duke Energy would have to install new pollution controls if it made modifications to its power plants that increased annual emissions without increasing hourly emissions. Well, never mind that, the EPA released a “rule” that “clarifies” this issue.

    EPA Accused of Flouting Supreme Court – washingtonpost.com

    The government proposed a pollution standard for power plants Wednesday that critics said flouts the spirit of a Supreme Court ruling on clean air enforcement.

    The proposal would make it easier for utilities to expand plant operations or make other changes to produce more electricity without installing new pollution controls.

    The proposal would allow the use of average hourly smokestack emissions when determining whether a plant’s expansion or efficiency improvements require additional pollution controls. The EPA hopes to make the proposal final before year’s end.

    Opponents of the hourly standard recently argued before the Supreme Court that this standard lets a plant put more smog-causing chemicals and other pollution into the air, even if hourly releases do not increase.

    Environmentalists long have contended the EPA should continue using annual emissions to determine whether new pollution controls are needed under the Clean Air Act.

    Let’s get this straight, “environmentalists contend”? There is nothing to contend here, it’s simple math. If you keep hourly rates the same and run your plant for longer, you will emit more pollution, which is not good. Less pollution good, more pollution bad, there is no point of contention here. Hourly standards and annual standards are used for two different things. The hourly standard sets a lower limit on the efficiency of the pollution control operation for the plant. The annual standard measures the plant’s overall impact. Both of them need to be regulated. It is only common sense that if you put out twice the amount of pollution in a year because you run 20 hours per day instead of 10, you need to control it. The Supremes rightly tagged this argument as dishonest, only to see the EPA very happily turn around and reissue it as an official rule.

  • GE Plumbs the Depths

    The very excellent htww blog by Andrew Leonard on Salon brought this “clean coal” video to my attention. It is a year old, but new to us!

    Do watch. In a one minute commercial, GE manages to greenwash on clean coal, be incredibly sexist, and, in an act that screams a giant F@#$ You to all involved, use as a soundtrack, a song about the misery of coal mining and the hardship faced by miners. I thought it was a parody, it had to be, apparently, NOT!

    Sixteen Tons

    Some people say a man is made outta mud
    A poor man’s made outta muscle and blood
    Muscle and blood and skin and bones
    A mind that’s a-weak and a back that’s strong

    You load sixteen tons, what do you get
    Another day older and deeper in debt
    Saint Peter don’t you call me ’cause I can’t go
    I owe my soul to the company store

    I was born one mornin’ when the sun didn’t shine
    I picked up my shovel and I walked to the mine
    I loaded sixteen tons of number nine coal
    And the straw boss said “Well, a-bless my soul”

    You load sixteen tons, what do you get
    Another day older and deeper in debt
    Saint Peter don’t you call me ’cause I can’t go
    I owe my soul to the company store

    I was born one mornin’, it was drizzlin’ rain
    Fightin’ and trouble are my middle name
    I was raised in the canebrake by an ol’ mama lion
    Cain’t no-a high-toned woman make me walk the line

    You load sixteen tons, what do you get
    Another day older and deeper in debt
    Saint Peter don’t you call me ’cause I can’t go
    I owe my soul to the company store

    If you see me comin’, better step aside
    A lotta men didn’t, a lotta men died
    One fist of iron, the other of steel
    If the right one don’t a-get you
    Then the left one will

    You load sixteen tons, what do you get
    Another day older and deeper in debt
    Saint Peter don’t you call me ’cause I can’t go
    I owe my soul to the company store

    Shame on them.

  • US Senate Bill on Global Warming

    Sanders, Leahy re-introduce Jeffords global warming bill – Boston.com

    “The good news is that we know how to address the problem. The bad new is that, for many years now, government policy has been totally inadequate,” Sanders said. “The forward-thinking legislation will put the United States on track to lead the way toward a cleaner future for all and I look forward to strong support as we push to protect our planet.”

    The bill was originally introduced in July of 2006, when it (predictably) went nowhere. Here is Sanders’ summary of the bill.

    The Global Warming Pollution Reduction Act calls for carbon dioxide (CO2) and other heat-trapping emissions to be reduced to 80 percent below 1990 levels by 2050.

    80% is the reduction called for in the Stern Review as well. The point is to stabilize global concentration at 450 ppm.

    It is still early to say what the prognoses in the Congress and Senate are, but one thing is sure, the US emperor will veto it. The point is, however, to establish this bill as the starting point of any negotiation/bargaining that will surely occur.

  • Fish good for You? – this byline stinks

    BBC NEWS | Health | Benefits of fish ‘outweigh risks’

    Dariush Mozaffarian, lead author of the study said: “Overall, for major health outcomes among adults, the benefits of eating fish greatly outweigh the risks.

    “Somehow this evidence has been lost on the public.”

    Concerns have been raised about chemicals found in fish from pollution.

    These include mercury, polychlorinated biphenyls (PCBs) and dioxins.

    And in other news, “breathing is good for you”. Please, I can’t take this any more. The question is NOT, and NEVER WILL BE, “Is fish good for you?”. Of course it is. The question is: “What kind of fish is good for you, and whether appropriate labeling can help the consumer decide”.

    At least in the US of A, which is where I have eaten the bulk of my fish, the primary source of information you can get about eating fish is on the web and for North Carolina, here. So, you’re supposed to go around with a checklist of good and bad fish in your head when you go to the grocery store. Most consumers do not have this kind of information, especially when there are so many categories to choose from. Is it fatty, or non? Is it freshwater or marine? Is it canned, fresh or frozen? Is it caught or farmed? Canned light tuna is okay, but canned albacore tuna is not, can you remember this when shopping for 30 other things at the store?

    Confused enough? How about, tilefish at 3.99 a pound versus salmon at 7.99 a pound? What will you buy on a tight budget?

    If you’re the average consumer, you have a minute to decide whether it’s fish for dinner, or something else, unless you’re carrying around this handy checklist in your hand/PDA (in which case you’re not the average consumer), you have two opposing thoughts in your head….

    1. I know that fish is good for me, so I need to eat more fish
    2. I know that certain fish is not good for me, especially if I’m pregnant/nursing/feeding kids – But I don’t know if this fish that’s on sale is on the safe list, or not.

    What will you do given that you have one minute to decide, you have no information in the store, and you have no one in the store looking out for you?

    And this paper wonders, and I paraphrase,

    “Somehow this evidence has been lost on the public”

    Labeling is important, information is power, if you’re buying fish, you want to know where it is from, what the average pollutant loadings of the fish from this area are, and what the advisory on this fish is, so you can make an informed choice in the one minute that you have. This has been widely researched, and the information is easily available (on the web, where you don’t shop for groceries). Is it too much to ask for a list to be posted wherever fish is sold? I guess it “hurts business”.

    Personal responsibilty is accepted, but if you do not give people the tools to make informed choices, it’s just a cynical ploy to shift blame, shift burden, and shift risk.

    This paper deserves to be read in full, so here’s the abstract. Needless to say, the study, funded in full by tax payer money through the National Heart Lung and Blood Institute, is behind a subscription wall.

    Fish Intake, Contaminants, and Human Health

    Evaluating the Risks and the Benefits

    Dariush Mozaffarian, MD, DrPH; Eric B. Rimm, ScD

    JAMA. 2006;296:1885-1899.

    ABSTRACT

    Context  Fish (finfish or shellfish) may have health benefits and also contain contaminants, resulting in confusion over the role of fish consumption in a healthy diet.

    Evidence Acquisition  We searched MEDLINE, governmental reports, and meta-analyses, supplemented by hand reviews of references and direct investigator contacts, to identify reports published through April 2006 evaluating (1) intake of fish or fish oil and cardiovascular risk, (2) effects of methylmercury and fish oil on early neurodevelopment, (3) risks of methylmercury for cardiovascular and neurologic outcomes in adults, and (4) health risks of dioxins and polychlorinated biphenyls in fish. We concentrated on studies evaluating risk in humans, focusing on evidence, when available, from randomized trials and large prospective studies. When possible, meta-analyses were performed to characterize benefits and risks most precisely.

    Evidence Synthesis  Modest consumption of fish (eg, 1-2 servings/wk), especially species higher in the n-3 fatty acids eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA), reduces risk of coronary death by 36% (95% confidence interval, 20%-50%; P<.001) and total mortality by 17% (95% confidence interval, 0%-32%; P = .046) and may favorably affect other clinical outcomes. Intake of 250 mg/d of EPA and DHA appears sufficient for primary prevention. DHA appears beneficial for, and low-level methylmercury may adversely affect, early neurodevelopment. Women of childbearing age and nursing mothers should consume 2 seafood servings/wk, limiting intake of selected species. Health effects of low-level methylmercury in adults are not clearly established; methylmercury may modestly decrease the cardiovascular benefits of fish intake. A variety of seafood should be consumed; individuals with very high consumption (≥5 servings/wk) should limit intake of species highest in mercury levels. Levels of dioxins and polychlorinated biphenyls in fish are low, and potential carcinogenic and other effects are outweighed by potential benefits of fish intake and should have little impact on choices or consumption of seafood (women of childbearing age should consult regional advisories for locally caught freshwater fish).

    Conclusions  For major health outcomes among adults, based on both the strength of the evidence and the potential magnitudes of effect, the benefits of fish intake exceed the potential risks. For women of childbearing age, benefits of modest fish
    intake, excepting a few selected species, also outweigh risks.

  • Bill to exempt factory farms from pollution laws

    pigSmell manure?

    FEED – May 2006

    Congress may exempt factory farms from pollution laws Large agribusiness companies are pushing their friends in Congress to exempt factory farms from the pollution reporting and cleanup provisions in key pollution laws. The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as Superfund) and the Emergency Planning and Community Right to Know Act (EPCRA) provide an essential safety net for protecting water supplies from livestock pollution and for providing warnings of toxic air emissions from factory farms. Over 140 representatives are supporting a bill, H.R. 4341, that would give this sweetheart deal to factory farms. The bill may soon be attached to a “must-pass” spending bill in an effort to speed this ill-conceived measure through Congress. Please call your representative and urge him or her to oppose this dangerous legislation. To learn more, read the Sierra Club’s fact sheet (pdf) on this issue.

    Factory farms tend to be located in rural areas next to communities that do not have the power to stop them/mobilize against them. This provision will further stack the deck against these communities. Anyone who thinks manure, pesticide runoff, ammonia, etc are not hazardous to the ecosystem and to human health needs to live next to one of these “farms”. I am hazarding a really wild guess that Congressman Hall (the sponsor) does not have to deal with issues such as these.