Nearly 14 years have passed since the enactment of the 1990 National Pollution Prevention (P2) Act. This formal national policy stated that pollution should be prevented at its source whenever feasible. Battelle has been helping industry, state and local governments, and the U.S. Environmental Protection Agency (EPA) implement policies, technologies, and communication systems to promote the use of pollution prevention as our national policy. As part of recent work with EPA’s Pollution Prevention Division, Battelle and its subcontractor Terrachord, conducted an extensive investigation to determine where and how pollution prevention has been integrated into environmental regulations. We found more than 150 examples of creative pollution prevention activities within or complementary to traditional single-media compliance and enforcement focused programs.

Examples of how P2 can be integrated into regulatory programs include:

• Agency inspectors becoming environmental educators and offering new solutions during a routine inspection
• Facility environmental managers selecting P2 alternatives and their permit writers including them in enforceable permits
• Enforcement actions leading to penalties and the facility responding by implementing a P2 project

To document these successes, an online database was developed with more than 40 detailed case studies (www.p2caseregistry.org). Thirteen of the best case studies from around the country were highlighted in an EPA publication, Pollution Prevention Pathways to Regulatory Compliance and Innovation. The publication documented effective pollution prevention regulatory integration, including three case studies from within each of the major media programs—air, water, and waste—and four that are multimedia in design and impact.

Battelle also has been supporting the development and use of online communication for pollution prevention. Battelle Pacific Northwest Division staff members have been supporting the Agency’s Pollution Prevention Resource Exchange (P2Rx) network of regional pollution prevention clearinghouses. Battelle Northwest staff members have worked closely with EPA and their P2Rx grantees to pilot a number of innovative information products including the development of web services-based information sharing tools that allow P2Rx centers to easily share information between websites. Battelle also has supported the program by aiding in strategic planning to address emerging information technologies that can be used by P2Rx grantees to improve the effectiveness of their information delivery.

As part of pollution prevention for specific chemicals, Battelle also has supported OPPT’s Pollution Prevention Division in the development and implementation of EPA’s multimedia strategy for persistent, bioaccumulative, and toxic (PBT) pollutants. PBTs are pollutants that are toxic, persist in the environment, and bioaccumulate in food chains, affecting all environmental media (air, water, waste). EPA sought to create an enduring cross-Agency system that would address the multimedia issues associated with priority PBT pollutants. The strategy was developed by a PBT Plenary group consisting of all EPA program offices and the Regions, under the direction of the Office Directors’ Multi-Media and Pollution Prevention (M2P2) Forum. Battelle was contracted early in the process to help develop the Agency-wide strategy in an effort to identify and reduce risks to human health and the environment from current and future exposure to PBT priority pollutants.

As the PBT strategy has evolved, Battelle has continued to assist EPA in the PBT process by providing technical support for the development of National Action Plans for several of the PBT chemicals, including alkyl-lead, mercury and compounds, octachlorostyrene, polychlorinated biphenyls (PCBs), benzo(a)pyrene, hexachlorobenzene, and the cancelled pesticides aldrin/dieldrin, chlordane, DDT, mirex, and toxaphene. Among other strategies for reducing risk due to PBTs that were incorporated into these action plans, pollution prevention strategies emerged as a priority in several cases. For example, the PCB action plan relies heavily on preventing future PCB exposures through promotion of voluntary decommissioning of PCB-containing equipment, and the pesticides action plan emphasizes the importance of clean sweep programs for preventing accidental releases from unused stocks of cancelled pesticides.

In our own operations and in our work with EPA, state and local governments, and industry, Battelle is committed to promoting pollution prevention as the pathway to regulatory compliance and to a better environment.

For more information, contact Ms. Jill Engel-Cox at (703) 875-2144, engelcoxj@battelle.org.