49 



program of the nineties incorporates principles of pollution prevention and right-to- 

 know to yield a toxics program very different from what was originally envisioned. 

 The existing chemicals program, now applies three complementary approaches: 



1. The chemical-specific approach addresses an individual chemical of concern, 

 such as formaldehyde. Since 1990, the Existing Chemicals Program has completed 

 119 RMl cases involving 494 chemicals. Of these 494 chemicals, 12 cases involving 

 73 chemicals went on to more in-depth analysis. 



2. The use- or technology-specific approach addresses groups of chemicals used for 

 particular purposes (for example, paint stripping) or in a particular technological 

 process (for example, printing). We are currently working on 6 use clusters which 

 address 276 chemicals. 



3. The facility-specific approach focuses on facilities, rather than individual chemi- 

 cals. Since we have begun facility specific analysis in 1993, we have been completed 

 5 cases. 



Each of these approaches is aimed at reducing or eliminating significant risks to 

 human health and the environment, using pollution prevention as the preferred ap- 

 proach. EPA believes that a preventive approach should be favored because it is 

 most likely to produce cost-effective strategies for reducing risks. Over the past 

 year, OPPT has completed or launched initiatives using each of these approaches. 



A recent formaldehyde initiative is an example of the chemical-specific approach. 

 In December 1993, the National Particleboard Association agreed to fund a year- 

 long study, at a cost of more than $400,000, focused on characterizing formaldehyde 

 concentrations in new housing. This pilot study will evaluate a testing methodology 

 for use in a follow-up effort to evaluate the contribution of pressed-wood building 

 materials and cabinets to elevated levels of formaldehyde in indoor air. This new 

 voluntary testing effort builds on voluntary action by industry to reduce formalde- 

 hyde emissions from particleboard flooring products. Industry recently incorporated 

 reduced emission standards into an American National Standards Institute (ANSI) 

 standard used in national and regional building codes. 



An example of a use-specific approach is the consumer/small shop paint-stripping 

 use cluster project. Nearly all paint strippers present some type of health, safety, 

 or environmental risk. This project, to be completed this fall, involves identifying 

 and comparing the risks associated with 45 chemicals commonly contained in 

 consumer oriented paint — stripping products. 



Using the facility-specific approach, initial OPPT analysis of TRI data revealed 

 that four industrial facilities were responsible for most of the nationwide releases 

 of a heavily produced chemical — 1,2-dichloroethane — which EPA has classified as a 

 probable hvunan carcinogen. Follow-up analysis and investigation narrowed EPA 

 concern to a single facility in Indiana. Information obtained by EPA indicated that 

 reductions in releases of this chemictd reported by that facility had not in fact oc- 

 curred. EPA and the State of Indiana are presently taking action to ensure that re- 

 leases fi-om that facility are reduced to acceptable levels. 



In addition to efforts to improve implementation of the existing chemicals pro- 

 gram, we have developed a bold new approach to increase the compliance with 

 TSCA Section 8(e), a critically important information-gathering tool that serves as 

 an "early warning" mechanism for keeping the Agency apprised of significant new 

 chemical hazards and exposures, and for satisfying the public's right to know about 

 these hazards. 



In reviewing a number of enforcement cases, we found that some companies may 

 have been misinterpreting TSCA Section 8(e) and EPA's corresponding policy. They 

 appeared to be improperly discounting the significance of information on the basis 

 of a "weight-of-the-evidence" risk assessment, despite our longstanding policy that 

 if certain serious health effects are discovered, that information should be consid- 

 ered for immediate reporting to EPA without further evaluation. Companies that 

 fail to report "substantial risk" data undermine the Section 8(e) advance reporting 

 intended by Congress. 



To improve compliance with Section 8(e) reporting requirements, EPA initiated a 

 voluntary Compliance Audit Program (CAP). Under the CAP, participating compa- 

 nies submitted delinquent Section 8(e) information and paid stipulated penalties up 

 to a $1 million ceiling. EPA has received over 10,000 Section 8(e) notices under the 



