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Re: Are some regs driving increased use of haz chemicals?



I am resending this because I don't think this was posted the first time
I replied.

----- Forwarded by John Sparks/DC/USEPA/US on 01/11/02 07:34 AM -----
                                                                                        
                    John Sparks                                                         
                                         To:     Listman <listman@wmrc.uiuc.edu>        
                    01/10/02 08:44       cc:                                            
                    AM                   Subject:     Re: Are some regs driving         
                                         increased use of haz chemicals?(Document link: 
                                         John Sparks)                                   
                                                                                        



One focus of EPA's Design for the Environment Program( DfE) is to
provide companies industry-wide with a systematic tool that helps them
assess and implement cleaner technologies.  This tool is the Cleaner
Technologies Substitutes Assessment or CTSA.  The CTSA is a compilation
report of an assessment of promising substitutes for a specific
technology and compares cost, performance, environment impacts and
health and safety of available alternative technologies.  A CTSA project
is a EPA-industry partnership that includes stakeholders from industry,
trade associations, academia, other governmental  agencies and other
pertinent stakeholders groups.   Working together, the partnership then
produces the CTSA report  that provides the industry with information
that enables them to make an informed choice among possible substitutes.

Multiple examples of projects where this approach is used are on our web
site, www.epa.gov/dfe

Some lessons-learned:  we have found that those who switch from a
regulated chemical to a non-regulated one do not necessarily make a
safer choice.   There have been instances where a potential unregulated
substitute posed a greater relative risk that the one being replaced.
The CTSA  approach helps an industry recognize this disparity.

An unofficial statistic:  In DfE projects many of the chemicals included
as part of an assessment are not found on a regulated list or, otherwise
regulated.  Of those not listed or regulated, our partnership have
found, that many pose significant moderate to high relative risk -- if
seen by the Agency as a "new" chemical, we would recommend further
regulatory action --- such as testing or, placement of controls, H&S
training, labeling, or a recommendation that alternative substances be
considered.





                                                                                            
                    Listman                                                                 
                    <listman@wmrc.uiuc        To:     p2tech@great-lakes.net                
                    .edu>                     cc:                                           
                    Sent by:                  Subject:     Are some regs driving increased  
                    owner-p2tech@great        use of haz chemicals?                         
                    -lakes.net                                                              
                                                                                            
                                                                                            
                    01/07/02 03:24 PM                                                       
                    Please respond to                                                       
                    Listman                                                                 
                                                                                            
                                                                                            




     Forwarded on behalf of Burton Hamner--Please reply to the P2Tech
     list or Mr. Hamner.
Thanks.


     Any input to this project will be much appreciated!
     Burton Hamner
     www.cleanerproduction.com

     Have environmental regulations, disclosure requirements, or product
     bans =
     caused companies to use more dangerous chemicals?  Anecdotal
     evidence, =
     mostly from developing countries, indicates that some companies are
     =
     using petroleum or alcohol-based solvents in place of CFCs.  This =
     produces more hazardous waste, more VOC air pollution and increased
     fire =
     risk, despite reducing ozone depletion. There is also some
     anecdotal =
     evidence that TRI / Pollution Transfer &Release disclosure
     requirements =
     caused firms to substitute away from reportable chemicals to others
     that =
     might have more of an impact than the TRI chemical. We are
     collecting =
     any evidence of these changes in risks that might be available.
     Our =
     objective is to promote better understanding of comparative risk =
     management in Cleaner Production and Pollution Prevention.  A =
     professional paper is being developed.  If you have any examples
     you can =
     share with us we will be grateful and contact you for further
     details.  =
     Please reply to=20
     Mark Cohen, Professor, Vanderbilt University
     Mark.Cohen@owen.vanderbilt.edu


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     Content-Type: text/html;
             charset="iso-8859-1"
     Content-Transfer-Encoding: quoted-printable

     <!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0 Transitional//EN">
     Any input to this project will be much=20 appreciated!
     Burton Hamner
     www.cleanerproduction.com

     Have=20 environmental = regulations, disclosure requirements, or=20
     product bans caused companies to use more = dangerous=20 chemicals?
     Anecdotal evidence, mostly from developing countries, =
     indicates=20 that some companies are using petroleum or
     alcohol-based solvents in = place of=20 CFCs.  This produces more
     hazardous waste, more VOC air = pollution and=20 increased fire
     risk, despite reducing ozone depletion. There is also some
     anecdotal evidence that TRI / Pollution Transfer=20 &Release
     disclosure = requirements=20 caused firms to substitute away =
     from=20 reportable chemicals to others = that might=20 have more of
     an impact than = the TRI=20 chemical. We are collecting any
     evidence of these changes in risks that might be = available.
     Our=20 objective is to promote better understanding of comparative
     risk = management in=20 Cleaner Production and Pollution
     Prevention.  A professional paper = is being=20 developed.  If you
     have any examples you can share with us we will = be=20 grateful
     and contact you for further details.  Please reply to=20
     Mark Cohen, Professor, Vanderbilt=20 University
     Mark.Cohen@owen.vanderbilt= .edu


     ------=_NextPart_000_0026_01C19772.B11B0B10--


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