Managing Comprehensive Rule Making: EPA's Plan for Integrated Environmental Management

Environmental policy suffers from an internal contradiction. On the theoretical level it is widely agreed that policy must take into account interactions between different parts of the environment. But in practice, legislation and rule making are dominated by media-specific strategies that give scant attention to the transfer of pollutants among media. The difficulties with controlling toxic substances have demonstrated the limits of controlling one medium, or one substance, at a time. Toxics require comprehensive regulation for several reasons. First, toxics cause serious damage to the health of humans and other species. Second, the number of potentially dangerous substances is large; around 66,000 chemicals are listed in the Environmental Protection Agency's (EPA's) inventory. However, only 5,000 chemicals have been studied to some extent, and detailed assessments of risk have been prepared for just a few hundred. Despite a large research effort we still do not know enough about toxics to target controls on the most serious threats to human health and the environment. Third, most scientists hold that it is impossible to set safe levels of exposure. Fourth, toxics are persistent, often migrate between media, and can produce powerful synergistic and additive effects. Fifth, intense attention of the public and the media to threats from toxic substances force frequent changes in governmental priorities. And finally, regulatory decisions must take into account that many toxic chemicals are useful products. Defining new control strategies that are scientifically sound as well as economically acceptable depends on progress in the imperfect art of linking evidence to decisions. Analysis of the pathways of a pollutant throughout its life cycle is needed before one can tell at which point, and how, it is best to intervene, and whether controls planned by one program office will transfer the