ES&T V I E W S
H
ver more stringent regulations and the rising costs of c o m p l i a n c e are pushing some environmental technology companies to explore the application of new, more cost-effective technologies. However, in doing so these professionals often encounter significant barriers. Although barriers to new technologies are found in virtually all sectors of the environmental technology industry, I will focus here on barriers to the use of new field analytical i n s t r u m e n t a t i o n (FAI) for characterization studies. The reasons for choosing FAI are many. First, these technologies are applicable to virtually all sectors of the environmental industry, from Clean Air Act compliance monitoring to pollution prevention via process monitoring to field characterization and long-term postclosure monitoring of contaminated sites. S e c o n d , recent a d v a n c e s in FAI t e c h n o l o g i e s m a y c o n t r i b u t e to enormous cost savings. Third, technological advances in biotechnology, microelectronics, fiber optics, and software are providing opportunities for development of new, compact instrumentation systems whose accuracy and precision rival traditional laboratory m e t h o d o l o g i e s . And fourth, innovative FAI technologies (and the support of their use) provide a significant o p p o r t u n i t y for U.S. manufacturers to establish and maintain a lead in the competitive international marketplace.
BARRIERS TO USING
FIELD
ANALYTICAL
TECHNOLOGY INSTRUMENTS AS AN EXAMPLE
ADOPTION BY
JOHN
MOORE,
J R.
Where we are today To assess and remediate contaminated sites worldwide with existing technologies w o u l d cost an estimated $500 billion to more than a trillion dollars. Site characterization can represent as much as 40% of total cleanup costs (1). Of the average 10 years that it takes to clean up a Superfund site, seven are spent studying, characterizing, negotiating, and developing a remediation plan [2). The strict reliance on offsite laboratory analysis for all samples collected contributes to this lengthy process. Views are insightful commentaries on timely environmental topics, represent an author's opinion, and do not necessarily represent a position of the society or editors. Contrasting views are invited. 0013-936X/94/0927-193A$04.50/0 © 1994 American Chemical Society
Environ. Sci. Technol., Vol. 28, No. 4, 1994 193 A
Typically, samples are collected in the field and sent to a laboratory for analysis. The results of the first phase of sampling and analysis are usually inadequate for the development of a remediation plan. On average 70% of the samples collected are nondetects, containing no contaminants (personal conversation with Sebastian Tindall, Bechtel Environmental, Inc., San Francisco, CA, July 1993). Therefore, a d d i tional trips must be made to collect samples for analysis in order to obtain an adequate " p i c t u r e " of the site. T h i s i t e r a t i v e a p p r o a c h is costly in part because of unnecessary, expensive analysis of samples that are "clean." Couple the number of sites that need to be assessed with t h e cost to perform each assessment, and one questions whether we can characterize all sites with the time and money available. The judicious application of FAI can alleviate many problems associated with current site characterization techniques. However, the broad acceptance of FAI is hindered by several barriers. The barriers The barriers encountered fall into three main categories: legislative, regulatory, and institutional. Table 1 lists the barriers and their impact on the adoption of new technologies. A l t h o u g h all these barriers play some role in whether a technology is adopted, I will focus on two of the more significant barriers to FAI: method approval and the balkanized regulatory system. Although method approval and the balkanized regulatory system are in separate categories in Table 1, they are inextricably linked. Many problems that product developers face in the method approval process (e.g., ill-defined, inconsistent reporting requirements; no definitive time frames) are a direct result of the splintered structure and culture of regulatory agencies. The environmental regulatory community is divided into various programs and offices (generally media-specific) at the federal, state, and local levels. This division may make some sense for the development and enforcement of regulations, but it severely hinders the review and acceptance of new technologies. For this article, EPA is used as a model for national policies most often emulated by state programs. In February 1993, EPA's Innovation Technology Council (ITC) published "Monitoring Method Ap194 A
proval System" (3). This document is useful for product developers, as it defines the approval process for monitoring methods within the various EPA programs. However, the d o c u m e n t also clearly illustrates the significant flaws in this a p proval process, flaws originating in EPA's balkanized structure. This document lists numerous programs within EPA that each have separate method approval processes and offices to which applications are submitted. Each program office has its own specific data reporting and validation requirements, and approximate method approval processing times that vary from 1 m o n t h to more than 2 years. For example, an i n n o v a t i v e t e c h n o l o g y for water quality monitoring is required to undergo separate (and at times conflicting) reviews before acceptance as a m e t h o d for d r i n k i n g - w a t e r , wastewater, and groundwater moni-
Despite the acknowledgment by regulatory officials that a problem exists, little substantive action has been taken. toring requirements for Superfund sites. The net result is a technology adoption process that varies drastically within EPA and baffles technology developers. This process, or lack thereof, is a significant barrier to all product developers, but is especially burdensome to small start-up companies. These companies generally do not have the time and money required to w e a t h e r the m e t h o d a p p r o v a l process. Savvy investors are aware that the EPA approval process is inconsistent and often difficult to predict both in length and outcome. Therefore, they are often reluctant to support the efforts of a start-up firm. This leaves the developers financially strapped and compromises their efforts to bring their product to market. At a time when there is much talk within the federal government of increasing America's competitiveness abroad and emphasizing environmental technologies,
Environ. Sci. Technol., Vol. 28, No. 4, 1994
it is unfortunate that U.S. manufacturers face such large hurdles to gain regulatory acceptance of new technologies. What can be done? EPA recognizes that a problem exists, and in January 1991 published the report "Permitting and Compliance Policy: Barriers to U.S. Environmental Technology Innovation" (4). The first of three reports on technology adoption by the Technology Innovation and Economics Committee (TIE), a standing committee of EPA's National Advisory Council for Environmental Policy and Technology, this report provided EPA with several recommend a t i o n s to facilitate t e c h n o l o g y adoption. These recommendations were as follows: modify permitting systems to aid the development and testing of innovative environmental technologies, implement permit processes to aid the commercial introduction of innovative technologies, encourage the use of innovative t e c h n o l o g i e s in c o m p l i a n c e programs, maximize the effectiveness of permitting and compliance improvements by supporting stakeholders, and identify and remove regulatory obstacles that inhibit innovative technologies for environmental purposes. In conjunction with the TIE Committee recommendations, I believe that EPA can mitigate the technology adoption barriers outlined in this article in one of two ways. First, it could publish performance requirements; any technology/method that can meet these requirements could be used for complying with regulations. New technologies and m e t h o d s w o u l d be r e v i e w e d by neutral third parties to obtain objective reviews for meeting these performance specifications. EPA has used this approach in the underground storage tank program, and technology developers have given it favorable reviews. The second approach would be to e s t a b l i s h an office w i t h i n EPA whose sole responsibility would be to review and approve new methods and technologies. An "Office of New Technology R e v i e w " would oversee the wide range of technologies being developed, from monitoring and instrumentation to remediation a n d w a s t e w a t e r processing. Within the realm of FAI, this office would develop a consistent and easily u n d e r s t o o d m e t h o d a p p r o v a l process. This process w o u l d inc l u d e specific m e t h o d a p p r o v a l
TABLE 1
Barriers to technology adoption Type and example Legislative Clean Water Act Clean Air Act Regulatory Permitting & compliance
Cause
Effect
Best available control technology Maximum achievable control technology
Technology "lock-in" with no market incentive for technology advances
Rigid structure
Lacks flexibility needed for new technologies Time delays and risks to investors Technology "lock-in"
Method approval
Inconsistent and ill-defined
Rule making
Long, involved process
Institutional Balkanized regulatory system Bureaucracy: both regulators and users Government review of technologies Risk aversion
Splintered, inconsistent review and acceptance Slow response to rapid technology advances Resource limited Lack of knowledge
Laurier L. Schramm
Inconsistent technology adoption and use Loss of sales for product developer while awaiting decisions Long, unnecessary delays for approval Unwillingness to try new technologies
time frames (with milestones) and consistent product data reporting r e q u i r e m e n t s , c o o r d i n a t e the review of all technologies, and provide technical and regulatory assistance for both the d e v e l o p e r s of technologies and future users.
Acknowledgment
Conclusion T h e c o s t of r e m e d i a t i n g t h e world's environmental problems exceeds the financial resources available. However, rapid technological advances in a variety of fields may offer cost- and time-effective solutions to these problems. The current process by which new technologies are reviewed and accepted is not as responsive as necessary. Despite the acknowledgment by regulatory officials that a problem exists, little substantive action has been taken (i.e., most TIE recommendations have not been acted upon). In a d d i t i o n to the two barriers that play a major role in the adoption of FAI technologies discussed here, the other barriers listed in Table 1 may be of equal or greater significance to FAI and other environmental technologies. They should be carefully considered as well. As we try to increase America's international competitiveness, it is critical that we develop policies that exp e d i t e t h e a d o p t i o n of n e w technologies, not hinder it.
References
Upon request, the author will supply a brief bibliography of articles and papers that demonstrate the efficacy of FAI. He may be contacted at MIT Sea Grant College Program, 292 Main St., E38-306, Cambridge, MA 02139; phone (617) 2534434, fax (617) 258-5730.
I Colloid and Interface Science
ACS Professional Reference Book
If you're involved in any aspect of colloid interface science, The Language of Colloid and Interface Science is a must-have book! Covering theory, experiment, and application, this volume provides the user with a handy reference to all the terminology found in colloid and interface science literature.
The author thanks the numerous individuals who contributed to this article through comments and encouragement. I also wish to thank the MIT Sea Grant College Program for generous support of my research.
(i)
(2) (3)
(4)
Lindsey, F. "Agency Activities to Encourage Innovative Environmental Technologies"; presentation at the 9th Annual Waste Testing and Quality Assurance Symposium, Arlington, VA, July 1993. Elliot, E. D. FOCUS 1992, 8(4), 10-11. "Monitoring Method Approval System"; EPA Office of Modeling Monitoring Systems and Quality Assurance: Washington, DC, Feb. 1993; 600/F-93-011. "Permitting and Compliance Policy: Barriers to U.S. Environmental Technology Innovation"; Report and Recommendations of the Technology Innovation and Economics Committee, EPA Office of the Administrator: Washington, DC, Jan. 1991; 101/N91/ 001.
John Moore, Jr., a research associate at the Massachusetts Institute of Technology (Cambridge, MA), is also director of the marine industrial affiliates program at MIT Sea Grant. His research interests include the assessment of emerging technologies and their application to the environmental field. He received a B.Sc. degree in ocean engineering and has completed graduate courses in environmental policy, technology assessment, and product and market development.
This dictionary provides brief explanations for the most important terms that may be encountered in a study of the fundamental principles, experimental investigations, and industrial applications of colloid and interface science. Current and older terms are included, as are crossreferences for important synonyms, abbreviations, and acronyms. It presents useful tables of collections of similar terms, acronyms having related but different meanings, and useful predictive equations for physical properties. Specific literature citations are given where the sources for further information are unique or difficult to find. Laurier L. Schramm, Petroleum Recovery Institute ACS Professional Reference Book 260 pages (1993) Clothbound: ISBN 0-8412-2709-8—$69.95 Paperbound: ISBN 0-8412-2710-1—$39.95
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