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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 28 1992
OFFICE OF
THE ADMINISTRATOR
MEMORANDUM
SUBJECT: EPA Definition of "Pollution Prevention"
FROM: F. Henry Habicht II
Deputy Administrator
TO: All EPA Personnel
EPA is seeking to integrate pollution prevention as an ethic throughout
its activities, in accordance with the national policy expressed
in the Pollution Prevention Act of 1990. Your individual efforts
to push development of new opportunities, approaches, and processes
to prevent pollution are impressive and exciting.
While the concept of pollution prevention is broadly applicable--a
tool to accomplish many environmental tasks--this memo attempts
to guide more consistent use of the term in our activities and written
materials. Pollution prevention requires a cultural change--one
which encourages more anticipation and internalizing of real environmental
costs by those who may generate pollution, and which requires EPA
to build a new relationship with all of our constituents to find
the most cost-effective means to achieve those goals.
The following EPA "Statement of Definition" is a formal embodiment
of what has been the Agency's working definition of pollution prevention,
and is consistent with the Pollution Prevention Act of 1990 and
the Agency's 1991 Pollution Prevention Strategy. It makes clear
that prevention is our first priority within an environmental management
hierarchy that includes: 1) prevention, 2) recycling, 3) treatment,
and 4) disposal or release.
While it is subject to further refinement, this definition should
provide a common reference point for all of us. As you review and
apply the definition in your work, please keep the following points
in mind:
- As always, whether the pollution prevention option is selected
in any given situation will depend on the requirements of applicable
law, the level of risk reduction that can be achieved, and the
cost-effectiveness of that option.
- Accordingly, the hierarchy should be viewed as establishing
a set of preferences, rather than an absolute judgement that prevention
is always the most desirable option. The hierarchy is applied
to many different kinds of circumstances that will require judgement
calls.
- Drawing an absolute line between prevention and recycling can
be difficult. "Prevention" includes what is commonly called "in-process
recycling," but not "out-of-process recycling." Recycling conducted
in an environmentally sound manner shares many of the advantages
of prevention, e.g. energy and resource conservation, and reducing
the need for end-of-pipe treatment or waste containment.
As EPA looks at the "big picture" in setting strategic directions
for the decade ahead, it is clear that prevention is key to solving
the problems that all our media programs face, including the increasing
cost of treatment and cleanup. In the common-sense words of Benjamin
Franklin, "an ounce of prevention is worth a pound of cure."
Please use the Statement of Definition of Pollution Prevention
in all of your EPA activities.
POLLUTION PREVENTION: EPA STATEMENT OF DEFINITION
(pursuant to the Pollution Prevention Act of 1990
and the Pollution Prevention Strategy)
Under Section 6602(b) of the Pollution Prevention Act of 1990,
Congress established a national policy that:
- pollution should be prevented or reduced at the source whenever
feasible;
- pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible;
- pollution that cannot be prevented or recycled should be treated
in an environmentally safe manner whenever feasible; and
- disposal or other release into the environment should be employed
only as a last resort and should be conducted in an environmentally
safe manner.
Pollution prevention means "source reduction," as defined under the
Pollution Prevention Act, and other practices that reduce or eliminate
the creation of pollutants through:
--increased efficiency in the use of raw materials, energy, water,
or other resources, or
--protection of natural resources by conservation.
The Pollution Prevention Act defines "source reduction" to mean
any practice which:
--reduces the amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or
disposal; and
--reduces the hazards to public health and the environment associated
with the release of such substances, pollutants, or contaminants.
The term includes: equipment or technology modifications, process
or procedure modifications, reformulation or redesign of products,
substitution of raw materials, and improvements in housekeeping,
maintenance, training, or inventory control.
Under the Pollution Prevention Act, recycling, energy recovery,
treatment, and disposal are not included within the definition of
pollution prevention. Some practices commonly described as "in-process
recycling" may qualify as pollution prevention. Recycling that is
conducted in an environmentally sound manner shares many of the
advantages of prevention--it can reduce the need for treatment or
disposal, and conserve energy and resources.
Pollution prevention approaches can be applied to all pollution-
generating activity, including those found in the energy, agriculture,
Federal, consumer, as well as industrial sectors. The impairment
of wetlands, ground water sources, and other critical resources
constitutes pollution, and prevention practices may be essential
for preserving these resources. These practices may include conservation
techniques and changes in management practices to prevent harm to
sensitive ecosystems. Pollution prevention does not include practices
that create new risks of concern.
In the agricultural sector, pollution prevention approaches include:
--reducing the use of water and chemical inputs;
--adoption of less environmentally harmful pesticides or cultivation
of crop strains with natural resistance to pests; and
--protection of sensitive areas.
In the energy sector, pollution prevention can reduce environmental
damages from extraction, processing, transport, and combustion of
fuels. Pollution prevention approaches include:
--increasing efficiency in energy use;
--substituting environmentally benign fuel sources; and
--design changes that reduce the demand for energy.
For more information contact:
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