The United States Environmental Protection Agency

1. The United States Environmental Protection Agency A Brief History of EPA And Personal Experiences Diane Buxbaum, MPH

2. Building an Agency, EPA’s Birth • EPA came into existence in December 2,1970 • That was the year of the first Earth Day--a day in which there was widespread public concern about issues of environmental health • William Ruckelshaus, the first EPA Administrator, sworn in on December 4, 1970, had to start from almost “0” • The stated goal was to “Protect Human Health and the Environment”

3. Where was the authority before EPA came into being • Department of the Interior • Pesticide Research • Water Quality Administration • Department of Agriculture • Pesticide Registration • DHEW • National Air Pollution Administration • Bureau of Water Hygiene • Bureau of Solid Waste Management • Bureau of Radiological Health • Pesticide Tolerance Research • Executive Office of the President • Federal Radiation Control • Environmental Radiation Standards • Environmental Systems Studiesof the CEQ

4. EPA at the Beginning • Under the Administrator and Deputy Administrator—Public Affairs, Legislative Liaison, International Affairs, Equal Opportunity • There were AAs for Planning and Management, Standards and Enforcement, General Council (lawyers), and Research and Monitoring

5. With Offices/Commissions • for Water Quality, Air Pollution Control • Pesticides, Radiation and Solid Waste

6. EPA Today, Headquarters, Washington, DC 12 Assistant Administrators • Administration and Management • Air and Radiation • Enforcement and Compliance Assurance • CFO • General Counsel • Inspector General • International Affairs • Environmental Information • Prevention, Pesticides and Toxic Substances • Research and Development • Solid Waste and Emergency Response • Water

7. 10 Regions

8. 10 Regional Administrators and Offices A number of ORD Laboratories National Center for Computational Toxicology National Center for Environmental Assessment National Center for Environmental Research National Health & Environmental Effects Research Laboratory 10 Regions

9. And More • National Homeland Security Research Center • National Exposure Research Laboratory • National Risk Management Research Laboratory • Plus many more in the hand out

10. More on ORD Laboratories—Where they are: Research Triangle Park, Washington DC, Cincinnati, Ohio, Athens, Georgia, Las Vegas, Nevada, Narragansett, Rhode Island, Gulf Breeze, Florida, Duluth, Minnesota, Corvallis, Oregon, Ada, Oklahoma,

11. Why Did and Do We Need EPA? Four Examples of Hundreds that I am certain you can think of • 1) The almost extinction of the Brown Pelican, Pelicanus occidentalis, due to DDT caused egg thinning. Many other species of birds were also affected

12. The Brown Pelican

13. Hunting in the past caused losses of pelican populations, but the most dramatic reductions were caused by pesticides such as DDT and endrin.  The threat of DDT is particularly insidious because it drastically lowers the number of offspring of pelicans by interfering with the formation of calcium, which results in the production of brittle, thin-shelled eggs that end up being crushed by an incubating parent. 

14. In 1972, the Environmental Protection Agency (EPA) banned the use of DDT in the U.S. and put heavy restrictions on the use of certain other pesticides.  One year later, a pelican recovery plan was put into action. Populations have since significantly recovered.

15. 2) A Second Example, The Donora, Pennsylvania Fog of 1948 • The small company town was blanketed for 4 days with toxic fumes from the US Steel smelting plant • It was Halloween, and there was a temperature inversion—warmer dirty air held down by cooler air • 20 people died, 14,000 were affected, and if it had not cleared when it did many more would have died

16. Who Knows of any other deadly fogs? • 1952 London a fog so thick that people could not even see their own feet lasted 4 days and was responsible for the deaths of about 12,000 people

17. This is an actual photo of London in 1952

18. 3) A Third Example—Burning Rivers • In 1969 the Cayuga River in Ohio, where industrial wastes were dumped burned • YES THE RIVER BURNED due to the chemicals and solvents dumped in the river

20. A Fourth Example: Love Canal, Buffalo, NY • Hooker Chemical (a subsidiary of Occidental Petroleum) had sold property to the Niagara City school board to build a school in 1953– The same property where they had dumped 20,000 tons of toxic chemicals and covered the wastes, perhaps to hide their action • They did add a disclaimer about the site in the sale, even though they knew it was for a school, no one actually seemed to realize the toxic waste was there • Soon homes were being built around the site • In 1977 and before, toxic wastes were discovered leaking out of Love Canal

21. An aerial view of the Love Canal Site

22. So What Happened? • In 1980 EPA and New York State paid to relocate the residents of Love Canal • In 1980 EPA pressed for passage of the Superfund legislation • In 1982, the Superfund paid for the cleanup of Love Canal

23. More History • Well, the rules or laws under which EPA functions are numerous—I will only mention a few—actually, you can read it in the handouts and go on line to get more information • CAA, Clean Air Act of 1970 • FIFRA, Federal Insecticide, Rodenticide and Fungicide Act of 1972

24. More History (I heard the moans) • EPA bans DDT in 1972 • Federal Water Pollution Control Act of 1972 and amendments -- became what is known as the Clean Water Act • TSCA, Toxic Substances Control Act or 1976

25. And More • RCRA, the Resource Conservation and Recovery Act of 1976—deals with solid and hazardous wastes and recycling • Superfund of 1980, Comprehensive Environmental Response Compensation and Liability Act • UST, Underground Storage Tank standards 1988

26. And More • Montreal Protocol ratified 1988 to ban ozone depleting chemicals • PPA, Pollution Prevention Act of 1990 • SPCC, Spill Prevention, Control and Countermeasure Control, 1991 • EPA proposes Hudson River PCB Cleanup plan in 2000

27. This has been just a partial list • The passage of these laws was not the end, many of them have been amended—updated, some many times, since they were first passed

28. And now to a more personal aspect. Some of my work at EPA. • I will cover only two programs that I have dealt with, even though I have worked in others—the Good Laboratory Practice program and the Healthcare/Academic Institution Compliance Initiatives

29. Good Laboratory Practice Program • I was the lead Inspector for 6 years, overseeing scientific studies undertaken to register pesticides under the Good Laboratory Regulations of FIFRA • GLP regulations came into being because it turned out that some studies that had been submitted to EPA in the 70’s were totally false

30. What we did when we inspected • We would go to a facility and begin by finding out how the substance being tested arrived • We followed the substance from arrival to test application, to storage and or disposal • We followed how the lab was run and how data were maintained

31. It was not only interesting, it brought me into the research lab and out literally in the field again after many years absence • It was FUN! • There was a facility where I was lead inspector in New Jersey -- It became the first case with major violations found under these regulations • But Craven Labs in Texas was hands down the big winner of being “bad” in 1990

32. What was interesting to me was seeing the science being done in various mostly excellent research facilities • What was very satisfying was finding the bad actors whose studies were poorly designed and/ or carried out, and seeing them either clean up or get out of the pesticide testing field • What was very fulfilling was knowing that I was helping to see that pesticides with the least negative environmental impacts were getting registered

33. Hospital and College/University Compliance Initiatives • In 1999 a very enthusiastic new employee, a hazardous waste inspector, was looking around for a new sector that needed to be brought into environmental compliance • EPA had inspected and worked with the biggies like the Dows and DuPont's and the GMs and GEs and the Mercks and the Orthos, platers, printers and dry cleaners • It came to this person that colleges and universities had laboratories and garages and heating plants, etc.---maybe this was the new sector

34. Well, it got bigger and I became the Compliance Assistance Coordinator • We have almost 400 academic institutions in Region 2 – New York, New Jersey, Puerto Rice and the US Virgin Islands • But when you went to the colleges/ universities, some of them had hospitals associated with them—the SUNYs and CUNYs here in NY, Rutgers in NJ, etc. • So we added about 500 hospitals to form a new hospital initiative

35. This is what was found at one academic institution

36. And this at another

38. And the following at hospitals The picric acid at one facility had to be taken out by the bomb squad and blown up

39. And this, as well

40. Exhibit VII-18 Picric Acid (Cont’d)

42. And what have we accomplished • We have, in our College/University and Hospital Initiatives, been able to encourage facilities to participate in our Voluntary Audit Policy Program -- to carry out self audits and disclose the violation found to us (tell us what you are doing wrong)—we often give them time to fix it up • And we inspect

43. As of December 2005 • 129 inspections of both sectors • 99 enforcement actions • 38 formal enforcement actions valued at over 4.3 million dollars • Resulting in settlements of almost 1.2 million dollars • 59 Audit Agreements with larger facilities • 247 Voluntary Disclosures • And over 3300 violations corrected

44. A Few Examples of Properly Managed Pollutants-Results Count!` • From RCRA over 200,000 lbs/yr of hazardous waste now managed properly • From SPCC over 1,244,000 gallons of oil are managed properly • 760 residential units comply with lead laws under TSCA • Under the CAA, at least 156,000 lbs of chlorofluorocarbons are being handled correctly

45. Contact Information Diane Buxbaum, MPH Hospital and Academic Institution Compliance Initiatives Coordinator EPA Region 2 Buxbaum.diane@epa.gov www.epa.gov is EPA’s web site http://www.epa.gov/region02/ is Region 2’s web site