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New Directions For Environmental Protection

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New Directions For Environmental Protection

Carol M. Browner
EPA Administrator
June 15, 1993

 1. Pollution Prevention: The New Environmental Ethic

The Pollution Prevention Act establishes a bold national objective for
environmental protection: "[That pollution should be prevented or reduced at
the source whenever feasible." This policy statement offers my thoughts on how
we can achieve that goal by making pollution prevention the guiding principle
for all our programs at the Environmental Protection Agency.

We have already taken concrete actions that reflect the Clinton-Gore
Administration's commitment to environmental solutions that reduce pollution
at its source. For example:

-- The Administration's budget request for the 1994 fiscal year includes a $33
million increase in spending for pollution prevention programs at EPA;

-- On Earth Day, the President announced his commitment to an Executive Order
establishing voluntary source reduction goals for procurement, and requiring
federal agencies to comply with Right-to-Know public reporting requirements
for toxic chemical wastes;

-- On May 25, I released new Pollution Prevention Act data on the type and
amount of toxic chemicals generated as waste, and announced my intention to
expand Right-to-Know to include different chemicals and sources of pollution.

We can take pride in each of these accomplishments, but we must go
further. We must build pollution prevention into the very framework of our
mission to protect human health and the environment.

The new focus on pollution prevention will require a significant change
in the way EPA carries out its responsibilities and advocates resources. The
discussion below explains the multiple dimensions of EPA's investment in
pollution prevention, and establishes basic principles to guide programs and
regions toward our goal of integrating prevention into the Agency's "corporate

This policy statement is only a starting point: if we are to succeed, we
must continually renew our commitment by questioning established practices,
working cooperatively across program and agency boundaries, and not hesitating
to acknowledge shortcomings as well as success stories. I know I can count on
your support as we work together to chart a new course for environmental

 2. Why Pollution Prevention?

When EPA was created in the early 1970's, our work had to focus first on
controlling and cleaning up the most immediate problems. Those efforts have
yielded major reductions in pollution in which we should all take pride. Over
time, however, we have learned that traditional "end-of-pipe" approaches not
only can be expensive and less than fully effective, but sometimes transfer
pollution from one medium to another. Additional improvements to environmental
quality will require us to move "upstream" to prevent pollution from occurring
in the first place.

Preventing pollution also offers important economic benefits, as
pollution never created avoids the need for expensive investments in waste
management or cleanup. Pollution prevention has the exciting potential for
both protecting the environment and strengthening economic growth through more
efficient manufacturing and raw material use.

3. Summary Of Objectives

Pollution prevention is influenced by a number of factors, including EPA
regulations and state programs, collaborative efforts that offer recognition
and technical assistance, public data, the availability of clean technologies,
and the practices and policies of large public agencies. To be effective, our
pollution prevention program must establish the following objectives for each
of these areas:

-- Regulations and Compliance: The mainstream activities at EPA such as
regulatory development permitting, inspections, and enforcement, must reflect
our commitment to reduce pollution at the source, and minimize the cross-media
transfer of waste.

-- State and Local Partnerships: Increasingly, state and local agencies are
the "face of government" for the general public. We will strengthen the
national network of state and local prevention programs, and seek to integrate
prevention into state and local regulatory, permitting, and inspection
programs supported with federal funds.

-- Private Partnerships: We will identify and pioneer new cooperative efforts
that emphasize multi-media prevention strategies, reinforce the mutual goals
of economic and environmental well-being, and represent new models for
government/private sector interaction.

-- Federal Partnerships: We must work closely with our counterparts in other
agencies to ensure that pollution prevention guides our management and
procurement decisions, and to pursue opportunities for reducing waste at the
source in the non-industrial sector.

-- Public Information/The Right-to-Know: We will collect and share useful
information that helps identify pollution prevention opportunities, measure
progress, and recognize success.

-- Technological Innovation: We will try to meet high priority needs for new
pollution prevention technologies that increase competitiveness and enhance
environmental stewardship, through partnerships with other federal agencies,
universities, states, and the private sector.

-- New Legislation: Where justified, we must not hesitate to seek changes in
federal environmental law that will encourage investment in source reduction.

4. Definition

EPA has defined pollution prevention as "source reduction" as that term
is explained under the Pollution Prevention Act, as well as protecting natural
resources through conservation or increased efficiency in the use of energy,
water, or other materials. EPA staff should continue to use this definition,
as elaborated in the Agency guidance issued in May of 1992.

The guidance makes clear that pollution prevention is not the only
strategy for reducing risk but is the preferred one. Environmentally sound
recycling shares many of the advantages of prevention - it can reduce the need
for treatment or disposal, and conserve energy and natural resources. Where
prevention or recycling are not feasible, treatment followed by safe disposal
as a last resort will play an important role in achieving environmental goals.
In all cases we must be guided by applicable statutory requirements.

5. Regulations And Compliance

Our first obligation at EPA is to fulfill the statutory responsibilities
we have been given by Congress. That generally means developing environmental
standards through regulation, and ensuring compliance through a system of
permits inspections, and enforcement actions. I firmly believe that strong
environmental requirements, if designed to encourage cost-effective compliance
strategies from industry, can promote pollution prevention and improve the
competitiveness of American industry.

We can take a number of actions to realize this potential. First, we must
work within the law to design and implement our regulations to provide
incentives for source reduction. That will mean better coordination of
different regulations that affect the same industry to reduce transaction
costs, minimize cross-media transfers of waste, and provide a clearer sense of
our long-term goals for the regulated community.

EPA's Source Reduction Review Project (SRRP), which is exploring how best
to encourage pollution prevention in the design and implementation of rules
affecting 17 high priority industries, is a good start toward this goal. I
also will expect programs to evaluate opportunities for preventing pollution
in each major proposed regulation, as the Pollution Prevention Act requires.

Second, we must encourage pollution prevention as a means of compliance
through our permitting, inspection, and enforcement programs, relying on the
first-hand experience of regions and states in this area. We can learn
valuable lessons from experiments like the Massachusetts Waste Prevention
F.I.R.S.T. project, through which the state promotes source reduction as the
principal means of correcting violations detected through multi-media

Finally, we need to collect better data on those cost savings that occur
when regulations encourage investments in cleaner, more efficient
manufacturing processes. As part of this effort, we must develop credible
measures of the economic value of natural resources protected through
prevention. We must also explore non-traditional alternatives, such as
life-cycle analysis, that help shed light on the advantages prevention can
offer in meeting our objectives.

6. State and Local Partnerships

The Clinton Administration has called for a full partnership between
federal, state and local governments in defining and carrying out national
policy objectives. We delegate so many responsibilities to states and
localities under federal environmental law; we simply cannot hope to offer
effective incentives for pollution prevention in permits or inspections
without their close cooperation. Furthermore, some states have served as
national laboratories for the incubation of exciting new multi-media
experiments in reducing waste at the source, and are often more in touch with
industry and public needs and how best to meet them. Several states also have
taken the lead in helping their citizens and businesses use energy more

We can explore different methods for offering state and local governments
more flexibility in the federal grants used to support delegated activities
like permitting, inspections, and enforcement actions. EPA's new guidance,
beginning in the 1994 fiscal year, encourages our regions to work with states
to adjust administrative procedures in grant work plans to make room for
pollution prevention investments. EPA regions and states should make maximum
use of this flexibility, working within the statutory limits that govern grant
eligibility. The guidance requires programs to report on legal barriers to
funding worthwhile state pollution prevention projects, so that we may consult
with Congress to seek appropriate remedies.

We also must trust our state partners with greater responsibility for the
Pollution Prevention Information Clearinghouse, which will facilitate
prevention technology transfer and technical assistance. Our Regional Offices
also have lead responsibilities in the allocation of State grant monies under
the Pollution Prevention Act and in the-use of Regional extramural resources
(i.e. the 2% funds) allocated to pollution prevention activities. We must make
effective use of these resources to support strong state and local pollution
prevention programs.

7. Private Partnerships

Collaborative efforts with industry or public agencies in many cases can
help us achieve results through pollution prevention more quickly than could
be obtained through regulation alone. For example, EPA's Green Programs to the
voluntary energy efficiency will play a critical role in helping meet our
obligations under the U.S. Action Plan to stabilize greenhouse gas emissions
by the year 2000.

Furthermore, regulations often do not reach the more complicated
corporate decisions needed to evaluate design, manufacturing, packaging,
distribution and marketing practices to reduce pollution and energy
consumption. We must encourage these efforts by entering into partnerships
with public and private organizations where such cooperation can produce
tangible environmental results. EPA's collaborative efforts - like the Green
Programs, 33/50 and Design for Environment -- offer encouragement, assistance
and public recognition to those companies and groups willing to commit the
resources needed to get the job done

Recently, these initiatives have expanded to include WAVE, a program to
encourage water conservation with the hotel/motel industry. Earlier this year,
EPA proposed an "Environmental Leadership" program to reward corporations
willing to go beyond compliance by making measurable commitments to pollution
prevention. EPA's FY 94 budget proposal requests a substantial increase in
funding for these programs, reflecting our commitment to achieve environmental
gains by working cooperatively with industry. These investments will
supplement, but not substitute for, regulatory approaches to pollution

8. Federal Partnerships

President Clinton's Earth Day speech challenged the federal government to,
"lead by example - not by bureaucratic fiat." Our government has a tremendous
impact on the environment as the nation's largest landlord, and its biggest
consumer of goods and services. Later this summer, we expect to complete
action on an Executive Order that commits federal facilities to publicly
report wastes and emissions under TRI, establishes a voluntary goal of cutting
federal TRI releases 50% by 1999, and builds pollution prevention into the
specifications and standards that guide federal purchases. EPA recognizes that
other federal agencies can create major opportunities for pollution prevention
through investments in new technologies, and through policies that shape
decisions in agriculture, energy, transportation, and the management of
natural resources. If we want pollution prevention to expand in these sectors,
we must form partnerships that take advantage of the authority and expertise
at other federal agencies.

9. Public Information/The Right-To-Know

Since pollution prevention is motivated in part by public information,
one of EPA's most important tasks is to collect and disseminate
"user-friendly" data that measures progress in reducing waste at its source.
The Toxics Release Inventory (TRI) as amended by the Pollution Prevention Act
now-requires 28,000 industrial facilities to publicly report on the amounts of
toxic chemicals generated as waste or released to the environment. These and
other environmental data have proved vital in helping industry to identify
opportunities to reduce waste and improve economic efficiency. Through public
disclosure, the TRI empowers local communities, State agencies and other
public interest groups to become stronger advocates for pollution prevention.

I am committed to strengthening the Toxics Release Inventory, both by
improving the quality of the information and by making more effective use of
EPA's existing authority to expand the scope of reporting to additional
chemicals and major sources of pollution. We will also make the information
more accessible and understandable to states and local communities that depend
on timely and accurate data.

EPA's public data bases are not limited to TRI. Preventing chemical
accidents also is important, and the Agency collects information on chemicals
that can present a hazard if released during an accident. Data collected under
laws such as the Clean Air, Clean Water and Resource Conservation and Recovery
Acts are important indicators of environmental risk as well as prevention
opportunities, and EPA must take steps to integrate this information and make
it more readily accessible to the public.

We cannot stop at collecting and interpreting data. We should encourage
public education, from the university to the grade school level, that
illustrates the importance of environmental protection and the benefits of

10. Technological Innovation

Cooperative efforts with universities, industry, and other Federal
agencies help raise awareness of prevention opportunities and attract leading
scientists and engineers to engage in demonstration, development, and research
focused on new prevention technologies. Accordingly, we must expand work with
groups like the Department of Energy and its National Laboratories, the
National Science Foundation, the National Institute for Standards and
Technology (NIST), states, and the private sector to advance both the
development of new pollution prevention technology and the effective delivery
of information about such technology to companies looking for more efficient
environmental solutions.

I want to make sure that some of the funding available through the
President's Environmental Technology Initiative is targeted to help small
businesses meet compliance requirements through pollution prevention while
remaining competitive. As part of this effort, I will expect our programs to
work together to identify small business needs so that we may target short
term technical assistance and long term cooperative research in developing
cleaner, more efficient technologies.

11. New Legislation

I am convinced that we can achieve many important pollution prevention
goals working under existing federal environmental laws. Where these statutes
present significant barriers to reducing waste at the source, however, we
should not hesitate to share this information with Congress and, if needed,
seek appropriate statutory changes. I want to be sure that any effort to seek
new authority is informed by fact. That is why it is particularly important to
gather specific and accurate information on legal barriers to source reduction
identified when developing regulations and negotiating grants with states.

12. Conclusion

I expect pollution prevention to continue to evolve at EPA. As we learn
more, no doubt we will have to make adjustments to our programs that reflect
new knowledge. In the final analysis, what is critical in our efforts to
advance pollution prevention is a willingness to take chances, to question
established practices and experiment with new ideas, and above all to
cooperate with each other as we try to harmonize environmental protection with
economic growth. I hope you share my excitement at the new possibilities for
pollution prevention in the Clinton-Gore Administration, and I look forward to
working with all of you to achieve the ambitious goals of this policy.