Methodology for pollution source reduction assessments of the manufacturing process chemistry in the US EPA's pre-manufacture notice reviews

Abstract The Office of Pollution Prevention and Toxics of the US Environmental Protection Agency (EPA) has initiated assessments of the pollution potential associated with the chemistry of chemical manufacturing processes in its review of pre-manufacture notices submitted by manufacturers of chemicals not on the Toxic Substances Control Act Inventory. The objectives of the assessments are to: (1) achieve pollution prevention by determining whether the process chemistry of a manufacturing process has significant raw material utilization inefficiencies, especially in terms of the generation of toxic substances in the waste streams, prior to the use of any control technology; (2) indicate, where possible, the causes for the inefficiencies and associated waste products; and (3) suggest possible approaches for reducing the use or generation of toxic substances. The rationale for such assessments is based on the idea that, as the use or generation of toxic substances is reduced or eliminated, the potential for exposure and releases, and therefore the risk, is correspondingly reduced. The methodology used in the assessments is described in this paper.