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MEMORANDUM


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

Office of the Administrator
May 28, 1992

MEMORANDUM

SUBJECT: EPA Definition of "Pollution Prevention"

FROM: F. Henry Habicht II /signed/
Deputy Administrator

TO: All EPA Personnel

EPA is seeking to integrate pollution prevention as an ethic throughout
its activities, in accordance with the national policy expressed in the
Pollution Prevention Act of 1990. Your individual efforts to push development
of new opportunities, approaches, and processes to prevent pollution are
impressive and exciting.

While the concept of pollution prevention is broadly applicable--a tool
to accomplish many environmental tasks--this memo attempts to guide more
consistent use of the term in our activities and written materials. Pollution
prevention requires a cultural change--one which encourages more anticipation
and internalizing of real environmental costs by those who may generate
pollution, and which requires EPA to build a new relationship with all of our
constituents to find the most-effective means to achieve those goals.

The following EPA "Statement of Definition" is a formal embodiment of
what has been the Agency's working definition of pollution prevention, and is
consistent with the Pollution Prevention Act of 1990 and the Agency's 1991
Pollution Prevention Strategy. It makes clear that prevention is our first
priority within an environmental management hierarchy that includes: 1)
prevention, 2) recycling, 3) treatment, and 4) disposal or release.

While it is subject to further refinement, this definition should
provide a common reference point for all of us. As you review and apply the
definition in your work, please keep the following points in mind:

-- As always, whether the pollution prevention option is selected in any given
situation will depend on the requirements of applicable law, the level of risk
reduction that can be achieved, and the cost-effectiveness of that option.

-- Accordingly, the hierarchy should be viewed as establishing a set of
preferences, rather than an absolute judgment that prevention is always the
most desirable option. The hierarchy is applied to many different kinds of
circumstances that will require judgment calls.

-- Drawing an absolute line between prevention and recycling can be difficult.
"Prevention" includes what is commonly called " in-process recycling," but not
"out-of-process recycling." Recycling conducted in an environmentally sound
manner shares many of the advantages of prevention, e.g. energy and resource
conservation, and reducing the need for end-of-pipe treatment or waster
containment.

As EPA looks at the "big picture" in setting strategic directions for
the decade ahead, it is clear that prevention is key to solving the problems
that all our media programs face, including the increasing cost of treatment
and cleanup. In the common-sense words of Benjamin Franklin, "an ounce of
prevention is worth a pound of cure."

Please use the Statement of Definition of Pollution Prevention in all of
your EPA activities.

POLLUTION PREVENTION: EPA STATEMENT OF DEFINITION
(pursuant to the Pollution Prevention Act of 1990 and the Pollution Prevention
Strategy)

Under Section 6602(b) of the Pollution Prevention Act of 1990, Congress
established a national policy that:

-- pollution should be prevented or reduced at the source whenever feasible;
-- pollution that cannot be prevented should be recycled in an environmentally
safe manner whenever feasible;
-- pollution that cannot be prevented or recycled should be treated in an
environmentally safe manner whenever feasible;
and
-- disposal or other release into the environment should be employed only as a
last resort and should be conducted in an environmentally safe manner.

Pollution prevention means "source reduction," as defined under the
Pollution Prevention Act, and other practices that reduce or eliminate the
creation of pollutants through:

--increased efficiency in the use of raw materials, energy, water, or other
resources, or
--protection of natural resources by conservation.

The Pollution Prevention Act defines "source reduction" to mean any
practice which:

--reduces the amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or disposal; and
--reduced the hazards to public health and the environment associated with the
release of such substances, pollutants, or contaminants.

The term includes: equipment or technology modifications, process or
procedure modifications, reformulation or redesign of products, substitution
of raw materials, and improvements in housekeeping, maintenance, training, or
inventory control.

Under the Pollution Prevention Ac, recycling, energy recover, treatment,
and disposal are not included within the definition of pollution prevention.
Some practices commonly described as "in-process recycling" may qualify as
pollution prevention. Recycling tat is conducted in an environmentally sound
manner shares many of the advantages of prevention--it can reduce the need for
treatment or disposal, and conserve energy and resources.

In the agricultural sector, pollution prevention approaches include:

--reducing the use of water and chemical inputs;
--adoption of less environmentally harmful pesticides or cultivation of crop
strains with natural resistance to pests; and
--protection of sensitive areas.

In the energy sector, pollution prevention can reduce environmental
damages from extraction, processing, transport, and combustion of fuels.
Pollution prevention approaches include:

--increasing efficiency in energy use;
--substituting environmentally benign fuel sources; and
--design changes that reduce the demand for energy.

For more information contact:
--the Pollution Prevention Policy Staff (202-260-8621), or
--the Pollution Prevention Division, Office of Pollution Prevention and Toxics
(202-260-3557)