by Carol M. Browner
[EPA Journal - July/September 1993]

No longer confined to special projects, the new approach will be integrated into all programs.

The Pollution Prevention Act established a new national policy for environmental protection: "that pollution should be prevented or reduced at the source whenever feasible..." This deceptively simple statement heralds a profound change in how EPA meets its obligations to protect human health and the environment. In the past, we emphasized "end of pipe" treatment of waste after it was produced. Today, we must move upstream in the manufacturing process to prevent the waste from being generated in the first place.

By now, the arguments for this change in emphasis are widely accepted as common sense. Improvements in treatment and disposal techniques have led to dramatic reductions in pollutant loadings, but they have proved costly, and they have barely kept pace with traditional problems, let alone managing new ones. Perhaps most disturbing, some of the investments driven by our single-media decision-making process have simply shifted waste from one part of the environment to another.

For example, wastewater treatment plants built to satisfy federal water quality requirements are now among the biggest sources of toxic air emissions at industrial facilities and in some urban areas. With environmental spending approaching 2 percent of gross national product by some estimates, it has become critical to ensure that our investment is as efficient as we can make it.

Pollution prevention is the answer. Reducing waste at the source not only minimizes the cost of treatment and the transfer of pollution, it can actually strengthen our economic competitiveness through more efficient use of raw materials. For example, the 1992 study by the nonprofit organization INFORM, Inc., documented savings of $21.8 million from source reduction activities at 14 chemical plants. Preventing pollution, then, offers the exciting possibility of reconciling economic growth with environmental protection to enhance the quality of life for ourselves and our children. What can EPA do to achieve the Clinton-Gore Administration's commitment to prosperity and a clean environment, two deeply held American values?

Actions always speak louder than words, and we have already taken steps to reflect our commitment. 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 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 additional chemicals and sources of pollution.

We can be proud of these accomplishments, but they are only a starting point. We must go further by integrating pollution prevention into all of EPA's traditional activities. At the same time, we must acknowledge that the fundamental nature of our base programs must evolve to create a more hospitable environment for the transition from "end of pipe" treatment to pollution prevention.

• That will mean more innovative use of traditional tools like regulations at the same time that we invest in voluntary programs that recognize industries for going beyond compliance.

• It will require us to work across program boundaries to coordinate different rules that affect the same industry, providing the regulated community with greater certainty and incentives to develop multi-media compliance strategies.

• It will require flexibility in grants to states, and improved working relationships with other federal agencies that have a profound influence on the environment through their own behavior or policies.

• It will mean strengthening public data programs that both measure and motivate progress in reducing waste at the source, while reducing burdensome paperwork requirements that serve no clear purpose.

• It will require strengthening our investment in technical assistance programs that help small businesses find more cost effective ways to comply with the law through pollution prevention.

Taken together, these changes in direction will lead to a "user friendly" EPA, without sacrificing our commitment to the highest standards of environmental performance. As a user friendly agency, we will establish clear and consistent expectations for states, the public, and the private sector, provide incentives for investments in pollution prevention in our regulatory and compliance programs, target information and technical assistance where it will do the most good, and eliminate redundant transaction costs.

None of this would be possible without the enthusiastic support that EPA employees have already shown for change. On June 15, I signed an Agency-wide policy statement establishing the basic expectations for the transition to pollution prevention. It builds on the first steps that EPA staff have already taken through initiatives like the Source Reduction Review Project, new grant flexibility for states, Design for the Environment, and the Green programs. It also announces a broader effort to build pollution prevention into the "corporate culture" at EPA.

Our transition to this new environmental ethic will succeed only if we are willing to question established practices, cooperate across program and agency boundaries, and not hesitate to acknowledge shortcomings as well as success stories. I know that EPA employees share my excitement at the expanded possibilities for pollution prevention in the Clinton-Gore Administration, as we work together to chart a new course for environmental protection.