Criticism of research planning at EPA
BJ
Richard M. Dowd The Science Advisory Board (SAB) of EPA has undertaken the most intensive review of EPAs research strategy since the 1975 National Academy of Sciences study of EPA decision making. Administrator Lee Thomas asked the SAB to advise him on improving strategic research planning at EPA. The SAB convened a committee, chaired by former deputy administrator AI A h , and released the committee’s report, “Future Risk: Research Strategies for the 1990’s.’’ this September. The report reflects serious, fundamental concerns about the research effort at EPA. It makes a series of farreaching recommendations, which, if implemented, should transform and redirect EPAs research program and its regulatory strategy. This column will examine the key problems the committee has identified; next month we will cover the report’s recommendations. The committee identified several major issues that l believe are worthy of wider discussion: an overemphasis on end-of-pipe controls at the expense of risk reduction strategies; significant gaps in the knowledge base; the need for improvements in monitoring; inadequate technology transfer activity; inadequate funding; and the lack of a long-term, coherent research strategy.
The issues The report stresses that the agency’s emphasis on end-of-pipe controls is no longer valid. End-of-pipe controls focus on large industrial sources of individual pollutants in specific media. Such controls do not necessarily result in a reduction of risk-they may result in a reduction of a particular pollutant 1146 Envimn. Sci. Technol.. MI. 22. No. 10. 1988
in a specific medium (e.g., SO, in air), but at the cost of an increase of a different pollutant in another media (e.g., sludge on the land). The committee believes these controls will be ineffective for the next generation of environmental problems, which will involve many small new sources-such as households, gas stations, and dry cleanersthat will be less susceptible to command and control regulations. The committee concludes that significant gaps exist in the knowledge base that is necessary for the understanding of several specific enviromental issues. Little information is available on the impact of contaminants on ecological systems or on humans, and very little is known about the health effects of mixtures of chemicals or of most synthetic chemicals in general commercial use. According to the SAB, information on toxicity is known for only about 20% of approximately 48,000 commercial synthetic chemicals. The committee thinks the monitoring data systems of the agency need improvement. In particular, the committee notes that the agency’s current monitoring effort focuses only on a few chemicals known to cause environmental problems. (In this area the committee is pulling its punches-its criticism of the monitoring program is much milder than in some past reviews.) The report suggests that EPA has not done enough to transfer the results of research, both information gathering and technology development, to individuals and institutions. Technology transfer is judged to be a particularly important issue because future regulatory issues will likely involve numerous small and uninformed sources. The report recognizes the state of EPAs budget crunch with respect to the research program (see May 1988 “Regulatory Focus”). Reductions in funds available for research at EPA have occurred, despite new responsibilities mandated by five major new statutes in the 1980s and several new pressing environmental problems. The report emphasizes the need for EPA to develop a core research pro-
gram that would provide fundamental understanding of the next generation of environmental problems. EPA does not have a process to help predict these problems nor even to begin research on issues that the agency knows will be a problem in the near future. (For example, EPA ranked potential environmental problems in its report “Unfinished Business” last year, but the research program has not responded to this effort.)
Reasons for lack of strategy The committee identified several reasons for the lack of a coherent research strategy: The research program responds primarily to the near-term needs of EPAs program offices. Research programs are often undertaken in response to immediate public and political concerns. The R&D program is considered primarily a tool for meeting short-term statutory mandates. Top management in the agency is not involved in deciding on a core longterm research program. The research program has not had consistent leadership. The report points out that in the 1980s no person has held the position of assistant administrator for R&D for even as long as two years. Challenges for EPA This report deserves careful consideration. Over the next decade environmental issues will become even more complex. The emphasis will continue to change from traditional to toxic pollutants, from national to global issues, and from large single sources to numerous small ones. Unless the foregoing problems are resolved, EPA will be illequipped to assist the nation in addressing this next generation of environmental issues. Next month-the solutions.
Richard M. Dowd, Ph.D., is president of R. M. Dowd & Company, scientific and environmental policv consultants in Washington. DC.
W15936W8810922-1146t01.5010 Q 1988 American Chemical Socieh,
