Document vg3eZdrxEg6O9wdLe2n6N6v6

TO: Distribution TG& Jjgfc: WT: M&fe >KjfRF XF:___ _________________ Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles December 6, 1989 ENVIRONMENTAL "FRIENDLY PRODUCTS" VIS1A Attached is an alert from CSMA regarding two EPA activities in the area of environmental friendly labeling. It appears EPA will be moving forward with plans to develop a consumer education process on relative environmental risks of products. I also heard from SDA today that Unilever Canada, is actively promoting phosphate free detergents as environmentally friendly. By copy of this memo, I am asking Joe and Mike to assure the CLER communications committee is aware of these issues. Cr^------- T. G. Grumbles dlj .905 Attachment Distribution: W. J. B. Vogel, Ron Bryan, Carl Kerfoot, John Roheim, Allen Nielsen, Mike Reynolds cc: J. C. Ledvina vvv 0000072T8 Founded ra CHEMICAL SPECIALTIES MANUFACTURERS ASSOCIATION M E M 0 R AND 0 M Suite 1t20 1001 Connecticut Avenue. NW Washington, DC 20036 202/872-8110 Telefax 202/872-8114 To: From: RE: All CSMA Members A^ E&Sf' (L_ EPA Project to Rank Consumer Products We have recently learned that the EPA/OAQPS has initiated a project to rank consumer products according to the environmental risk or (potential) hazard they pose. OAQPS has formed a consortium of various federal agencies, EPA program offices, environmental groups, and state organizations to inform the public that certain products pose environmental hazards. The project will focus on a class of consumer goods to be determined through four stages. Once a product group is chosen, EPA will perform an analysis of the human health and environmental risks associated with the products. A risk "score" will be applied to the products, and a report will be written for consumers and manufacturers to use in comparing product risks. Please review the enclosed document. The EPA- Office of Pollution Prevention has initiated another related project based on Europe's "blue angel". This blue angel label would be similar to a Good Housekeeping seal of approval on consumer products by designating which products are not considered harmful to the environment. We believe the scrutiny of our products by EPA and its consortium has no basis. We plan to address this issue Inmediately. We will meet with OAQPS (Mohin and McCullough) next week in Research Triangle Park, N.C. and Pollution Prevention later this month. For further information, please contact Soonie McDavid at (202) 872-8110. VVV 000007279 X, TITLE Con*u#f? Product Comparative ttieks Ksrket-based Pollution Pmtntioft. IX. LEAD OROAHIZATION Emission Standard* Division (BSD) Off lot of Air Qualify Planning and Standard* (OAQPS) Timothy xohin - iff 639-934# or Kelt*** McCullough - PTS 629-5446 IZX. GOALS AMO OBJECTIVES Every day, the American consumer make* dossns of decisions that nay have direct or indirect impact on public health and tfca environment. Paper bag or plastic at the grocery, stick deodorant or spray, cell the plumber or buy some chemical drain opener, cloth diaper* or disposable, fast food in styrofoam or paper -- these alternative* vary in ''the cumulative risk they create by their production, transportation, use and disposal. if consumers were aware of the comparative risk* of product alternatives, conscious choice could influence market demand. That this kind of approach can work is evidenced by the dramatic changes we have seen in the market place a* consumers have acted on health information regarding fiber, cholesterol, and chemical* in their foods, Because the scope i* broad and risk* involve consumer protection a* veil a* multi-media impact*, OAQPS will work with the CMC, rOA, MWTf industry group* end other ERA program office*. Our specific objective is to examine the full risks of some products from cradle to grave--to provide a screening evaluation which would result in the selection of a focused group of products , a detailed risk "scoring" of each of the. alternative focus product*, and then generic guidance for future work on how to perfens and* distribute comparative risk analyses for consumer product*. Our ultimate goal is that the public will become aware that everyday habits carry cost* and benefits and that they will weigh those out whan making consumer decisions, XV, SKPLjaoGHTATXOK PLAtf AMD SCHEDULES This project would be a cooperative effort involving the participation of geveral federal agencies and ERA program offices as veil a* other groups representing industry and anvirorxsatffeal interests (see Division of Responsibility below). The combined expert!** of these group* in the areas of human health uisk, cifiVironJMfhtal risk, consumer product* and public education would be employed on a steering committee * This committee would have responsibility to oversee large issues and concerns regarding the vvv 000007280 2 direction o the project, put specific management decisions on hev the study should bo conducted and expenditurs of resouroe* would ho delegated to a smaller group to ba ohaired by QAQFS* St it expected that this project will consist of four gonoral ttfke* Task It Screenings Months 0-6 a qualitative risk analysis of a vies range of products to develop* a focus on a class of products for the initial comparative risk study. This task would involve identifying groups of consumer products and ranking then as to their relative importance with regard to health and environmental impacts* Finally, the steering committee will choose a group of consumer products as the focus of this project* Task 3 s Risk analysisx Months 7 - IS This task would Involve an in-depth analysis of the human health ar- environmental risks associated with the group of consumer products selected in Task 1. Risks associated with all media will be estimated from raw material processing to final disposal of the focus product group, culminating in a risk score to be used for product comparison. Task 3? Report preparations Months 16 - 20 This task would result in a report directed at consumers and producers of the focus product group describing the cumulative risk associated with alternative products. Another report would also be developed that would provide an outline and guidance for future comparative risk projects involving other product groups* T&cX 4i Information distribution and evaluation: Months 21 - 24 The steering committee will decide on a communication strategy to distribute comparative risk information to the consumers and producers of the focus product group* This strategy will Include a public education aspect which will ensure that the risk information provided in the report will be easily accessible and understandable. In addition, an evaluation of the effectiveness of this approach to pollution prevention and guidance on how to replicate the approach for other product grout**, will be orsated based on the results from the pilot study. Dependent on the evaluation of the pilot study, the guidance document will be publicised as a tool for the expansion of this approach* VVV 0Q00Q7ZQI 3 V* PXQDUCTi AND OOWDT0 This project would create three products. i* ..flofflatiat* This will *> ft brief report with a qualitative risk analysis of ft wide ranee of alternative consumer products **- resulting from .Task 1. This will includei (a) As couplet* a Hat as possible of products used regularly in and around tha hoaa; and (b) a listing par-product of risk considerations, such ft* limited v renewable natural resource, recycl*hle/non~ biedegradabls/biodegradebis, toxic production aateriale# toxic production eolsslons/ef fluent, high transportation energy use, toxic us* eaissiond, frequency of product or disposal abuse, means of disposal and fate/ispacts after disposal, 2. Product group Rink Ajaf*ioynt ppport. Tbift document will contain the in*-depth risk analysis of tha focus group of producta--resulting fron Tasks 2 and 3. This will include! (a) An explanation of tha rationale for selecting the focus group of alternative products; and of tha sathods for scoring product risk! (b) a coaplste listing per product of tha risk considerations, such as those listed for Product 1 (b) above? <c) the scoring of- tha above risk considerations and ranking of the cumulative risk scores of tha alternative products; and (d) a conclusion regarding the risk assessment of tha alternative products* 3 * Inx&atfefclpn,.cc * This report will contain the risk ccnsaunlcation strategy developed in Task a* It will outline what information is aot important for dioaaninaticR, .what vehicles or nedia should be used for outreach, who should be targeted as an initial audience, hoy the risk* should be explained, and potential problems in conveying this risk information to the general public. The document will also contain sos* examples of information material such as posters, lables, 0#* and A'*# etc. VVV 000007282 vx* 4 orDXVtSXOH RESPONSIBILITY {This outline the division of responsibi1i11es es we plfcn At, please see footnote undo? Resources for details*) A. 8PA/0AQP8/PA& Chair steering committee Risk iMHistnt Kajor report writing n. Office of solid Hast# and Emergency Response office of water Offieo of Peetloldes and Toxic* Substances Consumer Product Safety commission rood and Drug Administration Servo on Starring Committee Provido risk oonaidaration information for area* of expertise ongoing raviov of written materials Provido ongoing advlee and comment c. national wildlife Federation Industry Group(s) representing producers of focus products Serve on steering committee Ongoing review of written materials Provide ongoing consent Assist in Risk Communication strategy VII* CONTRIBUTION TO PROGRESS IN POLLUTION PMVBNTieN This project proposes to prevent pollution at the pre~ production stage, by eliminating market desand for products with the most "risk" (in human and environmental health measures)* Public awareness of the full coats of our consumer products cen result .in a chpnge in consumer patterns and a snowballing effect. Concerns about cancer and heart disease made "high-fiber* and "cholesterol"- household words, often used in advertisements* similarly, public information about the total risk associated with a consumer product can change the market picture for both the consumer and the produoer. This kind of pollution prevention can be only one part of the pussle* Just as mobile source emissions art best reduced by a combination of carpooling, higher fuel efficiency ears and the cleanest fuels, so will production facility pollution be host minimised by adding together reduoed demand for "higher-risXs* products, more conventional pollution prevention Practices and# where necessary, end of pipe controls. Reducing demand will make the newt two steps much simpler* VVV 000007283 5 vxxx. AimuGorr amo xmuxxiox i Tte full of this product vill only bo maaaurabla war tim. Xovsvsr, a oontuaar survsy vill b# done in Took 4-- y 08m1r9 product uss, giving rlok information/ thn asking vhat chongoo consumers veuid mak* boood on ttet information* This would previds mono besio for expanding ite approach to otter products or not* XX. WCSOOKCES* ZX ,.9Q____________ T!L1FY *3________________ 22h OAQPS FT AC4C fTS 1*5 XC*G 130K TTS AC+C 1.5 150X 300X *Those agencies and organisations listed in Division of aeaponsibiiltiss vr not abl to provide tiaafces of ?TS` participation or concurrence maaoa. Wo have dicusted this proposal with the aenciss and all have expressed interact* Several have expressed tentative agreement to participate* VW 000007284