EPA Requests Sustainability Guide

December 5, 2010
Reprinted from Crosslands Bulletin, December 5, 2010

EPA Requests Sustainability Guide

A potential sea change in the U.S. could be launching slightly off course.

Ralph Cicerone, Paul Anastas and Bernard Goldstein
Answering questions at the launch of the Green Book study are (right to left) Ralph Cicerone, Paul Anastas and Bernard Goldstein.
Photo: Patricia Pooladi, NAS.

The US Environmental Protection Agency wants a logical, scientific system to follow to factor sustainability concepts into all its programs. The agency has asked the National Research Council (NRC) to formulate the procedure. The recommendations are due in nine months at the latest.

The request intentionally parallels the systematic risk assessment procedure produced by NRC for EPA in 1983. The risk management principles contained in what is now known as the Red Book form the foundation that underpins EPA’s regulations. EPA has already coined the title Green Book for the analogous sustainability framework. The Red Book method separated the analytic function of risk assessment from what had often become bitterly controversial policy decisions about human health hazards and ecosystem protection.

NRC is an institution of the National Academy of Sciences, whose honorary elected members advise the government on any subject from the safety of hamburger meat to protecting the country from terrorists. The person chosen to chair the ad hoc sustainability committee is Bernard Goldstein, a physician and an occupational health professor at the University of Pittsburgh. Goldstein has chaired a dozen National Academies scientific committees before this one.

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At the microphone, Ira Feldman of greentrack strategies

Paul Anastas, President Barack Obama’s choice to head up EPA’s Office of Research and Development, is shepherding the initiative through EPA. In 1983 Goldstein held the same job at EPA as Anastas does. A memo from Anastas to staff introducing himself and the path he sees going forward is available on the Web here.

The officer with administrative responsibility for the panel is Marina Moses, the director of the science and technology for sustainability program at NRC. Moses has on-the-job experience implementing the Red Book. She worked for EPA in New York City with Chief Administrator Lisa Jackson.

The membership of the sustainability committee has been posted on the project Web site. Besides Goldstein there are 10 people named provisionally. Eight of the 11 members are Ivy League graduates or previously worked at EPA. The public may comment on the membership for 20 days (the clock is already ticked down to 16) before the appointments are final. Names on the panel include Lauren Zelse, a cancer and reproductive toxicant risk specialist. Kenneth Ruffing is an independent consultant whose previous career was spent at the UN and the Organization for Economic Cooperation and Development. He wrote an introduction to a new book about sustainable economic development.

Leslie Carothers, president of the Environmental Law Institute, was the vp for environment, health, and safety at the military contractor United Technologies Corp. in the 1990s and the environment commissioner for the state of Connecticut before that. Carothers started her career at EPA in 1971. She, Goldstein, and a third committee member, Neil Hawkins, a vp for environment, health, and safety at Dow Chemical Co., are all members of the National Academies Roundtable on Science and Technology for Sustainability. Anastas is a roundtable member, too. Since 2002 the roundtable of about 40 people has been a talking shop on how to move the country towards sustainability goals. (see A Flicker of Interest in Sustainability Appears in Washington, 21 June 2004).

Sustainable Stoves

Secretary of State Hillary Clinton announced the Global Alliance for Clean Cookstoves at the Clinton Global Initiative forum in September 2010. The goal is for 100 million homes to adopt efficiency stoves and fuels by 2020.

The public-private alliance is led by the United Nations Foundation. The US EPA is one of more than 20 founding partners, including governments and UN agencies. The US EPA is promising $6 million over the next five years to test stoves and new designs, and to assess their health benefits of reducing people’s exposure to smoke. For information contact Global Alliance for Clean Cookstoves, 1800 Massachusetts Avenue NW, Suite 400, Washington, DC 20036, USA. Tel: +1 202 650 5345; Fax: +1 202 650 5350; E-mail:cookstoves@unfoundation.org.

EPA timed the launch to coincide with weeklong events celebrating the agency’s 40th birthday. EPA was created with the stroke of a pen by President Richard Nixon on 2 December 1970.

The administration’s press announcement of the NRC study cited the Global Alliance for Clean Cookstoves, in a distracting but revealing aside, as exemplifying EPA’s idea of sustainability thinking. “The initiative does not merely focus on reducing risk, but it forges a sustainable solution linking environmental issues such as air quality and deforestation to health and quality of life issues for women and girls” (see sidebar).

More than science

At an announcement ceremony in Washington, DC, after speeches by National Academies President Ralph Cicerone, Administrator Jackson, and Goldstein, the first person to the microphone during a 15-minute question period was Ira Feldman, a former special counsel in the Office of Enforcement & Compliance Assurance at EPA. Feldman developed and directed EPA’s corporate Environmental Leadership Program, the first of its kind at the agency.

Feldman is a big-picture environmental and sustainability consultant. He homed in on EPA’s one-dimensional perspective of sustainability and on the insular nature of National Academies studies.

“I think this is a very important day, one I have been waiting for for a long time — for EPA to embrace sustainability,” Feldman said. “What has led to the decision to have the National Academies embark upon a process that covers all EPA programs as opposed to [those of] the Office of Research and Development, given the science and technology orientation of the National Academies’ existing roundtable and presumably of the committee?”

Paul Anastas replied: “When we look at the foundations of EPA, one of the things that you will hear in an unwavering voice is that all of our decisions, all of our actions, need to be based in sound science with the highest degree of scientific integrity. So it actually is not unusual that when we turn to that new level of awareness and look at the sustainability approach, that the construct for that sustainability framework is in the body of work that has been referenced over the past 20 years of sustainability science. Because the work of the agency is based in science, as we proceed across the work in all aspects of what EPA does, sustainability and science will go hand-in-hand.”

For all its many virtues, the Red Book’s regulatory risk assessment process bogged down. Some assessments for chemicals take more than 10 years. For trichloroethylene and others it has been 20 years. A different NRC panel of experts had this to say: “Stakeholders — including community groups, environmental organizations, industry, and consumers — are often disengaged from the risk-assessment process at a time when risk assessment is increasingly intertwined with societal concerns. Disconnects between the available scientific data and the information needs of decision-makers hinder the use of risk assessment as a decision-making tool.”

EPA asked for the independent study to identify improvements that the agency could make in the risk assessment process. The committee gathered data for the study from the third quarter of 2006 through the winter of 2008. EPA was told to retain the Red Book process wth a crucial change that bears on the sustainability endeavor. The report says “risk assessment should be viewed as a method for evaluating the relative merits of various options for managing risk rather than as an end in itself.

“Risk assessment should continue to capture and accurately describe what various research findings do and do not tell us about threats to human health and to the environment, but only after the risk-management questions that risk assessment should address have been clearly posed….

“Well-designed risk-assessment processes create products that serve the needs of a community of consumers, including risk managers, community and industrial stakeholders, risk assessors themselves, and ultimately the public.”

The report is available here.

The ad hoc committee for operationalizing sustainability at EPA plans a public workshop in Washington, DC, on December 14 and 15, followed by a closed meeting in Southern California in February 2011.

“Are there other meetings? Are they also closed?” Feldman asked. “The National Academy, unfortunately, does not have a great track record of having open meetings to other experts in the field. It would be nice to see a different process come about for that.” Feldman mentioned the desirability of getting buy-in from other sustainability groups and initiatives in the US that might have complementary expertise to offer.

Responding to the procedural question, Goldstein said: “I hope that everybody would be willing to contribute what they know to the committee’s process.

“Please if you have ideas, if there is something you would like to communicate, we will be very happy to receive it and I am sure the committee will take it into account.”

Space is going to be limited at the first meeting. Seats will be available on a first-come first-serve basis, with an RSVP to sustainability@nas.edu 5:00 pm, December 13.

For information contact Paul Anastas, US EPA, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W. , Mail Code: 8101R, Washington, DC 20460, USA. Tel: +1 202 564 6620: E-mail: anastas.paul@epa.gov. Science & technology for Sustainability Program, E-mail: sustainability@nas.edu. Ira Feldman, Greentrack Strategies, P.O. Box 34088 Bethesda, MD 20827 , USA. Tel: +1 202 669 1858; E-mail:ira@greentrack.com.


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