Reducing toxics a new approach

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donors.

About the Pollution Prevention Education and Research
Center
The Pollution Prevention Education and Research Center (PPERC)
addresses a broad range of issues associated with industrial production
processes and the use of hazardous materials. The Center’s mission is to
conserve resources and reduce or eliminate the use of toxic substances
through an interdisciplinary program of education, research, and outreach
grounded in a philosophy of prevention rather than control. Through the
collaborative efforts of its members, PPERC is shifting the focus from
“end-of-pipe” pollution control techniques to a front-end, systems

approach which analyzes technologies, cycles of production and consumption, industrial structures, and policy instruments to reduce toxics use and
protect human and environmental health.


Reducing Toxics



Reducing Toxics
A NEW APPROACH
TO POLICY AND
INDUSTRIAL
DECISIONMAKING

Edited by
Robert Gottlieb

Pollution Prevention Education and Research Center
University of California, Los Angeles

Washington, D.C. • Covelo, California


Copyright © 1995 by Island Press

All rights reserved under International and Pan-American Copyright conventions. No part of this book may be reproduced in any form or by any means
without permission in writing from the publisher: Island Press, 1718
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ISLAND PRESS is a trademark of The Center for Resource Economics.

Library of Congress Cataloging-in-Publication Data
Reducing toxics: a new approach to policy and industrial
decisionmaking / edited by Robert Gottlieb.
p. cm.
Includes bibliographical references and index.
ISBN 1-55963-336-0 (pbk.)
1. Pollution—Government policy. 2. Industrial management—
Environmental aspects. I. Gottlieb, Robert, 1944–
HC79.P55R43 1995
94-46257
658.4’08—dc20
CIP
Printed on recycled, acid-free paper
Manufactured in the United States of America
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Contents

Contributors
Acknowledgments

xi
xiii

Introduction

1
Robert Gottlieb and Janice Mazurek

PART I
The Difficulty of Getting There:The Evolution of Policy
1

The Pollution Control System:Themes and Frameworks
Robert Gottlieb and Maureen Smith
Managing Pollutions: Policy Conundrums
Seeking Change:The Emergence of Pollution Prevention
Conceptual Themes in Pollution Control
Policy Tools in Pollution Control

2

By Air,Water, and Land:The Media-Specific Approach to
Toxics Policies
Robert Gottlieb, Maureen Smith, and Julie Roque
Introduction
Air
Water

Land
Media-Specific Administration
Conclusion

3

10
13
17
20

25
26
33
40
44
49

Shifting to Prevention:The Limits of Current Policy
Janice Mazurek, Robert Gottlieb, and Julie Roque
Introduction
TSCA’s Lost Opportunity
Reconfiguring Single-Medium Regulation
The Ambiguities of Pollution Prevention Legislation and
Regulation
Conclusion

58
59
67

73
85

vii


viii

4

Contents

Disassociating Toxics Policies: Occupational Risk and
Product Hazards
John Froines, Robert Gottlieb, Maureen Smith, and Pamela Yates
The Problem of the Workplace
The Occupational Safety and Health Act
The Role of Standards
Acceptable Risk—Benzene
Setting Priorities at OSHA—Problem Identification
Enforcement—Are Pollution Prevention Strategies Available?
Consumer Product Hazards

5

95
98
99
103
105

108
110

New Approaches to Toxics: Production Design, Right-toKnow, and Definition Debates
Robert Gottlieb, Maureen Smith, Julie Roque, and Pamela Yates
The Debate Over Terms and Strategy
The Debates
Toxics Use Reduction and Pollution Prevention
Right-to-Know:The Role of Information
Reducing Government’s Role: Comparing Risks, Creating
Markets, and Emphasizing Technologies
Locating Other Entry Points: State and Local Efforts
The Terms: Linking Definitions to Policy
Barriers to Prevention
Pollution Prevention: An Environmental and Industrial Strategy

124
125
128
131
139
143
149
153
154

PART II
Industry Settings: Opportunities and Limits for Pollution
Prevention
6

Greening or Greenwashing?:The Evolution of Industry
Decisionmaking
Robert Gottlieb, Maureen Smith, and Julie Roque
Cautionary Precedents:The Tetraethyl Lead Case
What Gets Decided: Organization and Management Issues
Toxicology and Risk Assessment
Environmental Audits and Life Cycle Analysis
Green Marketing and Labeling
Environmental Citizenship
Decisionmaking and Production Outcomes

170
176
177
180
188
194
197


Contents

7

The Chemical Industry: Structure and Function
Maureen Smith and Robert Gottlieb
Introduction
Engine of Growth/Toxic Generator
Establishing an Analytic Framework

8

209
210
220

The Chemical Industry: Process Changes and the Search for
Cleaner Technologies
David Allen
Clean Technology and the Chemical Industry
Clean Technology Options
Process-Related Wastes and Emissions
Control and Management Techniques: Costs and Trends
The Opportunities for Cleaner Technologies
Restructuring Processes
Product Redesign and Raw Material Substitution for Waste
Reduction
Potential for Cleaner Technologies—Industry-Wide Perspectives
Conclusion

9

ix

233
235
237
246
248

262
263
269
273

Pollution Prevention for Emerging Industries:The Case of
Electric Vehicles
Julie Roque
Separating Industrial Design and Environmental Management
Electric Vehicles: “Clean” Products?
Analyzing Industrial Processes: Using Lifecycle Analysis
The Manufacture of Electric Vehicles
Operating Costs
Data Needs and Gaps
Measuring Wastes and Hazards
Plastic Components
Electric Motors
Electronics
Batteries
Conclusion

277
278
280
283
284
287
289
296
298

300
303
311

10 Substituting for Lead:The Radiator Repair Industry
Tamira Cohen, Rania Sabty, and John Froines
Resisting Change
Industry Background

332
334


x

Contents

Radiator Repair Process
Lead in the Workplace: Exposures and Risks
The Occupational Safety and Health Lead Standard
Control Strategies
Substitutions:The Primary Strategy for Prevention
Eliminating Risk:The Need to Intervene

335
338
342
344
348
353

11 The Aerosols Packaging Industry: Product Concerns
Pamela Yates and Robert Gottlieb
Products as Hazards
The Rise of the Aerosols Industry
The Structure of the Industry
Product Manufacture
Environmental Exposures
Occupational Exposures During Production
Exposures from Product Use
Regulatory History
Conclusion

359
361
364
368
370
373
374
377
381

12 Pollution Prevention Voluntarism:The Example of 3M
Peter Sinsheimer and Robert Gottlieb
Company with a Conscience
The “Business” of Innovation
3M’s Environmental Issues
The Rise of 3P
Environment and Product Design:Two Examples

Regulatory Issues
Conclusion

389
390
394
396
404
409
413

Conclusion: Barriers and Opportunities for Pollution
Prevention
Robert Gottlieb

421

Glossary of Acronyms
Index

429
433


Contributors
DAVID ALLEN is a codirector of the UCLA Pollution Prevention Education
and Research Center. He is professor and chair of the UCLA Department
of Chemical Engineering. He has written extensively on pollution prevention education and industrial ecology and served on a number of national
advisory committees on pollution prevention, including EPA’s American
Institute for Pollution Prevention and the Pollution Prevention Group of

EPA’s National Advisory Council for Environmental Policy and
Technology (NACEPT).
TAMIRA COHEN is a Ph.D. candidate in the UCLA Department of
Environmental Health Sciences in the School of Public Health, focusing on
issues of industrial hygiene and occupational safety and health.
JOHN FROINES is a codirector of the UCLA Pollution Prevention
Education and Research Center and professor of toxicology and chair of
the Department of Environmental Health Sciences at UCLA. He is also
director of the UCLA Center for Occupational and Environmental Health,
is a member of the National Academy of Science’s Committee on
Environmental Epidemiology, and was deputy director of the National
Institute for Occupational Safety and Health (NIOSH).
ROBERT GOTTLIEB is a codirector of the UCLA Pollution Prevention
Education and Research Center and coordinator of the Environmental
Analysis and Policy area of the UCLA Department of Urban Planning. He
has written extensively on environmental, resource, and industrial policy,
including Forcing the Spring, War on Waste, Thirst for Growth, and Empires in
the Sun.
JANICE MAZUREK is a research associate with Resources for the Future. She
holds a master’s degree in urban planning and is a Ph.D. candidate in the
UCLA Department of Urban Planning. She was formerly a senior research
associate with the UCLA Pollution Prevention Education and Research
Center.
JULIE ROQUE is a codirector of the UCLA Pollution Prevention Education
and Research Center and is an assistant professor in the UCLA Department
of Urban Planning. In 1994 she was on leave from UCLA as a senior policy analyst in the Office of Science and Technology Policy. At OSTP she

xi

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Contributors

was engaged in a wide range of projects, including evaluating management
and legislative strategies for toxics, and reviewing the White House’s proposal for a national environmental strategy.
RANIA SABTY has a master’s degree in public health and is currently a Ph.D.
candidate in the UCLA Department of Environmental Health Sciences,
focusing on industrial hygiene and occupational health and safety.
PETER SINSHEIMER is a senior research associate with the UCLA Pollution
Prevention Education and Research Center. He is a Ph.D. candidate in the
UCLA Department of Urban Planning and received a master’s degree in
public health at the University of California, Berkeley.
MAUREEN SMITH is a senior research associate with the UCLA Pollution
Prevention Education and Research Center. She is the author of The Paper
Industry and Sustainable Production: An Environmental Argument for Industrial
Restructuring, to be published later this year.
PAMELA YATES is an environmental audit manager for a Fortune 500 company. She is also a Ph.D. candidate in the UCLA School of Public Health
and was a senior research associate with the UCLA Pollution Prevention
Education and Research Center.


Acknowledgments
This book is a collaborative effort of faculty and researchers associated with
the UCLA Pollution Prevention Education and Research Center. The
Center was established in 1991 to address a broad range of issues associated
with industrial production processes and the use of hazardous materials.
The Center’s mission is to conserve resources and reduce or eliminate the
use of hazardous materials through an interdisciplinary program of education, research, and outreach embedded in a philosophy of prevention. This
book emerged in part out of the need to identify and analyze such an

approach.
As editor of this volume, I have appreciated the enormous value of collaboration. As part of that process, each of the codirectors of PPERC,
including myself, Julie Roque, John Froines, and David Allen, made specific
contributions as authors and/or coauthors of several of the chapters. A
major role in research and writing for the book was undertaken by
PPERC’s current or former research associates, Maureen Smith, Janice
Mazurek, Pamela Yates,Tamira Cohen, and Peter Sinsheimer, each of whom
authored or coauthored one or more chapters. Janice Mazurek also played
a crucial role in restructuring and ultimately cohering the overall manuscript. Research assistance for several of the chapters was provided by
PPERC research associates Deborah Fryman, Andrea Gardner, Peter Hein,
Joseph Powers, Helene Wagner, and Nola Kennedy. Linda Ashman Hicks,
PPERC’s associate director, reviewed the overall manuscript and made
important changes that both strengthened and refined the final product.
Funding for the project was provided by the University of California Toxic
Substances Research and Teaching Program and the UCLA Center for
Occupational and Environmental Health.
Ultimately, each of these individual efforts was part of the collaborative,
interdisciplinary model of research and analysis that the Pollution
Prevention Education and Research Center has sought to foster. It is an
approach we see as essential to the task of establishing this new paradigm
for policy and decisionmaking.

xiii



Introduction
Robert Gottlieb
Janice Mazurek

As we approach the new millennium, citizens in the U.S. and throughout
the world have begun to forcefully insist that the range of environmental
hazards present in everyday life needs to be reduced in all its manifest forms.
This argument has become particularly linked to the generation, use, and
disposal of toxic and hazardous materials. Successful reduction strategies
depend in part on expanding present interpretations of what we understand to mean “environmental hazard” or “toxics.” The term toxics as it is
referred to in this book, would in fact include all materials and processes
which may cause harm to human health and the environment.
For more than two and a half decades, various government policies and
industry responses have been developed to manage hazards present at each
stage of the production cycle. These policies and activities, however, have
failed to significantly address the problem of toxics generation and use
beyond the question of management and disposal. At best, more narrowly
conceived and at times contradictory efforts toward reducing these hazards
have been introduced both in policy arenas and through industry activities.
Yet, the greater the public focus on toxics, the greater the pressure on government and industry to more fully develop new strategies or new paradigms for policy and industrial decisionmaking. One starting point for analyzing such a shift in strategies is by distinguishing between two key
contrasting approaches in the policy area, most often characterized as prevention and control, and by identifying two contrasting reference points
along a continuum for industry decisionmaking, from public input and intervention to voluntarism.
With respect to policy, pollution control has remained the dominant
framework for most forms of legislative and regulatory interventions and
industry responses during much of this two-and-a-half-decade period. In
the process, a vast number of businesses and support services have been
established, including waste disposal, engineering and construction companies, and consulting and specialized control technology firms. These businesses collectively constitute an “environmental” or pollution control
industry, a direct product of the legislative and regulatory focus on the
management and treatment of environmental hazards.
Despite its dominance as a set of policy instruments and limited success
in addressing immediate and visible forms of emissions, the pollution con1


2

R. Gottlieb and J. Mazurek

trol system nevertheless became problematic in terms of its stated objectives. For one, media-specific, end-of-pipe regulations often failed to sufficiently address toxics, a pernicious and often hard to pinpoint subset of
pollution whose genesis, use, and exposure routes often departed radically
from nonhazardous pollutants related to household solid waste, thermal
water emissions, or partially treated sewage. Subsequent prevention-based
statutes, such as the Toxic Substances Control Act of 1976, seen as alternatives to the single-media, end-of-pipe focus, nonetheless failed in part
because of the statute’s limited depiction of toxic uses. As discussed in this
study, toxics reduction requires distinguishing among the nature, use, and
location of hazardous substances—a framework absent from the end-ofpipe statutes.
In addition to analytic distinctions, the regulations also posed practical
problems. For one, the economic costs of pollution control became
increasingly prohibitive. During the 1970s and 1980s, both disposal and liability costs rose dramatically, creating pressures on policymakers and industry to move beyond their preferred focus on management and treatment.
Cost created added implementation pressures as EPA increasingly bore the
burden of proving its programs cost effective. New political pressures arising in opposition to the construction or continued operation of treatment
and/or disposal facilities also forced policymakers to seek ways to shift
some of the focus away from pollution control toward new kinds of policy instruments aimed at minimizing or reducing wastes.This shift has been
most pronounced in the area of hazardous wastes, where control strategies
turned out to be most costly. Pollution control outcomes, as a public health
or environmental objective, also were seen as limited or contrary to the
stated goals of this policy system. Hazards throughout the production cycle
were shifted or transferred by medium and/or escaped regulatory purview,
while the emphasis on technology add-ons (such as scrubbers) or engineering controls (such as respirators) failed to address the problem of toxics generation and use. Similar to the debates over costs, the continuing
presence and at times concentration of hazards in new forms via pollution
control established both an environmental and public health interest in a
policy shift.As pollution control fell out of favor, waste minimization, then
pollution prevention, gained increasing support; indeed by 1990, with the
passage of the Pollution Prevention Act, this concept had become the
buzzword of environmental policymaking.

While policymakers engaged in efforts to shift toward a preventionbased framework, industry leaders responded by emphasizing their preference for voluntary action as distinct from regulatory interventions. Even as
the most prominent polluting industries learned to adjust to end-of-pipe


Introduction

3

control requirements during the 1970s and simultaneously supported market incentives as a better way of achieving environmental objectives (while
maintaining decisionmaking control), the new interest in prevention (and
related heightened public concerns about waste issues) also caused a shift
in focus during the 1980s for industry groups. Led by such companies as
3M and trade groups such as the Chemical Manufacturers Association
(through its “Responsible Care” program), industry sought to construct
through its voluntarist perspective a “corporate environmentalism.” Yet the
arguments that emerged about this approach, similar to the policy debates
within and among government agencies and legislators, revealed unresolved and contentious issues, primarily focused on decisionmaking questions.
In this book, we have developed a more comprehensive definition of
reduction or prevention that seeks to eliminate hazards in all environmental media. The definition is expanded along the production chain to
encompass not only environmental releases but occupational exposures
and product use. This definition requires new ways of exploring public
input and intervention, including the use of conventional policy instruments such as environmental taxes, product or substance bans, or regulatory instruments, including facility-wide permitting. Preferably, this new
type of approach will also be able to help renovate the process of industry
decisionmaking during the design phase—well before the product is manufactured, marketed, and consumed. Criteria questions for pollution prevention call for a critical examination of what is being produced, why it is
produced, as well as how it is produced. Such criteria must be central considerations for industry decisionmaking, and must parallel such core industrial design and structure criteria as costs, markets, product innovation, production efficiency, and material and process flexibility.These criteria must
be applied to the continuum of the industrial cycle; both upstream from
the production process, in materials extraction, as well as downstream, in
consumer use, recycling, and disposal.These criteria and debates surrounding implementation and strategies are developed in Chapter 5.
Despite the growing interest in developing a new framework for toxics
policy, the transition from control to prevention continues to remain an

elusive objective for policymakers, generators, and citizen groups. At the
same time, there has been no systematic examination of the nature of that
transition and the issues involved.The situation is comparable to earlier discussions of waste minimization: in the early 1980s when the concept was
first introduced, there were no comprehensive laws at the state level and
only a few which even partially incorporated waste minimization objectives. By the mid 1990s, however, nearly every state in the country had


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R. Gottlieb and J. Mazurek

established waste minimization legislation and related mechanisms for
implementation.1 Over the same period, the published literature on the
subject had increased significantly.Today, at an early stage of pollution prevention discourse, a review of the academic, trade, and technical literature
indicates a relative dearth of material on the concept and practice of prevention or reduction, despite the rapid increase in related policy initiatives
currently underway.
This book illustrates how pollution prevention emerged from the extant
control framework and analyzes the initiatives and policy debates which
have shaped their development and influenced the effectiveness of that
framework. Proceeding from the general to the specific, Part I examines
the regulatory and institutional setting of these initiatives and prescribes
possible definitions and strategies for developing a prevention framework,
the subject of the part’s concluding chapter. These principles are then
applied through case study analysis at the industry and facility level, the
subject of Part II.These snapshots, which target different “decision points”
in the production process, clarify definitions developed in Part I and
develop evaluative techniques for various approaches to pollution prevention. Such a framework is crucial in understanding the intent and limits of
particular legislative and industry initiatives, as well as in evaluating the
ability of such initiatives to reach their stated environmental goals.Through
analysis of these case studies, the authors explore the potential conflicts

between industry-supported voluntarist approaches and more publicly
framed, prevention-based policies. Based on the structural and organizational analyses of pollution prevention presented in Parts I and II, we conclude that pollution prevention still lacks coherence in terms of its definition, institutional implementation, and day-to-day application.
Reducing Toxics is a collaboration among faculty and research associates
affiliated with the Pollution Prevention Education and Research Center
(PPERC), an interdisciplinary program at the University of California at
Los Angeles. PPERC includes participants from the Department of
Chemical Engineering, the Center for Occupational and Environmental
Health within the School of Public Health, and the Environmental
Analysis and Policy area of the Department of Urban Planning.2 By integrating engineering, toxicological, and public policy approaches within
this new framework of pollution prevention, the authors have sought to
directly confront the complex of unresolved issues now facing policymakers and industry. This book represents the contextual starting point for a
longer term investigation into how certain environmental hazards, which
arguably represent some of the most protracted and unmanageable prob-


Introduction

5

lems confronting policymakers today, can be addressed in the years to
come.
We began this book seeking to answer a basic set of questions: what is
the nature and extent of pollution prevention research and activity currently underway, and how can these efforts eventually be designed in a
more comprehensive and holistic manner? This book addresses the first
question and establishes a framework of inquiry and analysis for the second. Ultimately, answering the question of feasibility—can pollution prevention become the option of choice for policymakers and industry?—
requires full public discussion of the issues at stake.This book, we hope, will
contribute to that process.

Notes
1. U.S. General Accounting Office, Pollution Prevention: EPA Should

Reexamine the Objectives and Sustainability of State Programs, (GAO/PEMD94–8), 1994; see also An Ounce of Toxic Pollution Prevention: Rating States’
Toxics Use Reduction Laws, (Boston and Washington D.C.: National
Environmental Law Center and the Center for Policy Alternatives, 1991);
State Legislation Relating to Pollution Prevention, (Minneapolis: Waste
Reduction Institute for Training and Applications Research, Inc., 1991).
2. See University of California Pollution Prevention Education and
Research Center, Program Description and Summary of Activities, 1991–1994,
(Los Angeles: UCLA Pollution Prevention Education and Research
Center, 1994).



Part I

The Difficulty of
Getting There:
The Evolution
of Policy
Robert Gottlieb

If the 1970s was, in the environmental policy arena, the decade of pollution control, and the 1980s was the decade when pollution policies began
to shift toward such approaches as waste minimization and marketing
incentives, then the 1990s has clearly come to be defined as the decade of
pollution prevention. But legislation and policy directives notwithstanding,
policymakers are still asking just what pollution prevention means.
Pollution prevention is a concept in search of a policy framework. Its
definitions remain contested, its terrain remains unclear. Is pollution prevention a form of exhortation by way of technical assistance, an encouragement of the market to achieve presumably more efficient outcomes, or
a new type of planning? Is it a matter exclusively for environmental agencies and regulators, or does it necessarily address other arenas such as workplace and product regulation? More than an abstraction but still less than
a coherent policy, the pollution prevention initiatives and debates of the
1990s in fact point to some of the problematic features of environmental

policymaking itself in a period when the role of government has become
the subject of a highly charged debate. And while pollution prevention has
become widely accepted in its broadest, least-focused terms, examining the
evolution of toxics policy from the 1970s to the 1990s serves the function
of better understanding how we got to where we are today, as well as sort7


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R. Gottlieb

ing out pollution prevention’s multiple reference points and diverse implications for policy.
Part I of Reducing Toxics examines how we shifted from the dominant
pollution control discourse to the more open-ended and often ill-defined
pollution prevention approaches that have emerged during the past decade.
The origins and development of pollution control during the 1970s, the
authors of Chapters 1 and 2 argue, involved a complex process with sometimes unintended outcomes, influenced significantly by certain dominant
assumptions and biases in environmental policymaking. Constructed in an
era of rising environmental advocacy, great urgency in mitigating visible
problems of pollution, increased reliance on a federal role in regulating
such pollutants, and a continuing belief that solutions were primarily technical in nature and that technologies could be located to address the pollutant of the moment, pollution control policies were developed as part of
an ambitious but largely unimplementable agenda. At the same time (as
Chapter 3 authors have described) there were other potential paths for
environmental policymaking, including the 1976 Toxic Substances Control
Act, that were never sufficiently explored. Those initiatives were constrained in part by the prevailing structures of policymaking, resistance
from the regulated, and an unwillingness of policymakers to follow the
logic of such new policies into the hitherto proprietary domain of industry decisionmaking.
The pollution issues, notably the question of toxics generation and use,
were not exclusive to the environmental domain, where policies were most
concerned with the endpoint in the flow of toxics or pollutants, specifically the management of wastes at their point of release into the environment.The focus on toxics generation and use shifted the focus to include

questions of both production (how things were produced) as well as consumption (what things were produced and what they were used for) rather
than environmental management as external to those processes (e.g., postproduction or postconsumption wastes). But policymaking in the areas of
workplace and product safety regulation, as discussed by the authors of
Chapter 4, remained even more distant than environmental policy from
the sources of the pollution or the hazards embedded in production and
consumption processes. By the 1990s, however, pollution prevention
appeared to be fully on the rise, as the authors of Chapter 5 discuss. But
the nature of that paradigm shift in policy, whether in terms of the definition of such policy, the role of information, the search for new policy
instruments, evaluations of risk, or the reemergence of state and local governments as major players, has been filled with uncertainties and ambiguities, making it, at the very least, an open-ended process.


Part I. The Difficulty of Getting There

9

Thus, we come face to face with a core dilemma in contemporary environmental policymaking. It is better, as is now commonly accepted, to prevent or reduce at the source various forms of environmental hazards or
(more generically) pollution itself, rather than to simply manage such pollution, once it has become a problem requiring attention. But there is neither consensus nor a significant number of examples of successful policymaking in how to prevent pollution.To resolve such a dilemma—the need
to make pollution prevention a successful and implementable guide to policy in light of the uncertainties of how or even whether to undertake such
policies—becomes then the task of environmental policymaking in the
years to come.


1

The Pollution Control System:
Themes and Frameworks
Robert Gottlieb
Maureen Smith

Managing Pollution: Policy Conundrums

At the heart of contemporary toxics policy reside a series of conundrums.
For at least a century, policies related to human health and the environment
reflected what was considered to be a basic truth of contemporary industrial society: that many products and materials produced and used by industry, including those that were hazardous, have made “life worth living,” as a
notable chemical industry promotional campaign once declared.1
Increasingly, policymakers are confronting the fact that these same products
and processes potentially pose widespread risks to human health and the
environment.To resolve this dilemma of production, an elaborate set of legislative and regulatory initiatives at both the federal and state levels were
developed to address the concerns about toxics. More generally, policies
focused on the larger issue of pollution as a whole.Yet most such initiatives
remained aloof from core production decisions regarding what to produce,
how to produce, and why specific materials and processes were used.
Although these early policies, which imposed high costs of regulation,
focus on the endpoint of the production process, they also served to highlight opportunities for intervention in the early stages of production, when
decisions regarding what to produce are made. Debates over these policies
ushered in new forms of environmental conflict over the degree and nature
of public intervention in production activities and decisions.
Opportunities for intervention first occurred in a significant way during
the 1960s, when growing public concerns about environmental hazards
increased pressure on Congress to authorize federal funds aimed at reversing the most visible forms of environmental pollution. Prior to this period,
federal efforts for the most part had been limited to grant programs to ease
10