Pollution Prevention as Defined Under the Pollution Prevention Act of 1990

Following passage of the Pollution Prevention Act of 1990, the U.S. Environmental Protection Agency (EPA) developed a formal definition of pollution prevention and a strategy for making pollution prevention a central guiding mission. Under Section 6602(b) of the Pollution Prevention Act, Congress established a national policy that:

This hierarchy of preferred options for dealing with environmental pollution officially places prevention at the top of the list.

According to the EPA's official definition, pollution prevention means "source reduction" as defined in the Pollution Prevention Act, but also includes "other practices that reduce or eliminate the creation of pollutants through (1) increased efficiency in the use of raw materials, energy, water, or other resources, or (2) protection of natural resources by conservation." Source reductionis defined under the Act as any practice which:

Thus, pollution prevention can be thought of as roughly synonymous with source reduction---reducing the generation of wastes or contaminants at the source, and thereby reducing releases to the environment that could pose hazards to the environment and pub lic health. Like source reduction, pollution prevention as defined by the Pollution Prevention Act does not include out-of-process recycling, waste treatment, or combustion of wastes for energy recovery.

The exclusion of recycling from the official definition of pollution prevention activities has been a source of controversy. Strictly speaking, recycling is not a form of prevention. However, recycling can confer substantial environmental improvements a nd can aid in conserving valuable resources. Thus, industry has argued that recycling should be on par with pollution prevention, since it represents progress toward reducing environmental pollution and achieving greater efficiency in resource use. The EPA has held fast to the more strict interpretation of pollution prevention which excludes recycling because even wastes that are effectively recycled have not been prevented (else they would not exist to be recycled!). However, the position of re cycling as the second highest option in Congress's and the EPA's pollution prevention/waste management hierarchy attests to its desirability as a goal in cases where wastes cannot be feasibly prevented. Furthermore, in some cases in-process recycling --- in which materials are directly reincorporated back into the same process --- is considered a form of pollution prevention.

Related Concepts and Terminology

Because P2 is a newly developing field, there is a lot of terminology being used by different groups and individuals, not all of which is yet well defined or consistently used. Some of the terms, such as source reduction,are essentially synonymous with pollution prevention, as discussed above. However, there are many other terms which, although related to pollution prevention, have specific meanings or usages. The following is a brief explanation of some of the more common terms. A note of caut ion: the definitions provided here may not coincide in all cases with the meaning intended by some authors or sources.

Pollution prevention itself is a term that can have a variety of meanings, depending upon who is using it. Although the EPA's definition is perhaps the most widely known, others have defined pollution prevention to include recycling and reclamatio n activities (activities which Congress and the EPA specifically exclude). For example, a draft standard being prepared by the American Society for Testing and Materials (ASTM) on the development and implementation of pollution prevention programs define s pollution prevention as "the act of reducing or eliminating the use, release or generation of a pollutant or potential pollutant through source reduction, recycling, reuse, reclamation or modification of existing practices." (Source: ASTM E50.03 Subcom mittee on Pollution Prevention, Reuse, Recycling and Environmental Efficiency, Standard E50.03.1: Guide for Development and Implementation of a Pollution Prevention Program. Working Document, January 24, 1994. Standard is available from ASTM Cus tomer Service Department by calling 215/299-5585.)

Waste minimizationwas one of the first initiatives in the area of pollution prevention, and focused almost exclusively on solid wastes regulated under the Resource Conservation and Recovery Act (RCRA) --- particularly hazardous wastes. (Source: U. S. EPA, Pollution Prevention 1991: Progress on Reducing Industrial Pollutants. Washington, DC: Office of Pollution Prevention, U.S. EPA, October, 1991. (EPA 21p-3003) pp. 6-7.) Thus waste minimization is much narrower than the current definition of pollution prevention, which focuses on reducing the entire spectrum of pollution and waste, including air emissions, releases to surface and groundwaters, and inefficient energy and materials use, in addition to waste (in the traditional sense) which is s ent off for land disposal, treatment, or off-site recycling. Waste minimization has been controversial since it has often included treatment methods to reduce the volume or toxicity of existing waste, rather than focusing solely on minimizing the amount of waste being generated at the source. Recent RCRA reporting requirements now exclude treatment and energy recovery from the definition of waste minimization activities. However, unlike the EPA's definition of pollution prevention, waste minimization d oes includes recycling in addition to source reduction activities. (Source: Henry Freeman et al., "Industrial Pollution Prevention: A Critical Review." Journal of Air and Waste Management42, no. 5 (May 1992) 619-620.)

Waste reductionis a term that falls somewhere between waste minimization and pollution prevention. Waste reduction has a broader focus than waste minimization with its emphasis on RCRA hazardous wastes, but implies a narrower perspective than poll ution prevention with its holistic approach to preventing all types of pollution released to all environmental media from products as well as from industrial processes. Use of the term waste reduction is not widespread, perhaps in part due to its ambigui ty.

Toxics use reductionis the elimination or avoidance of using toxic substances in products or processes so as to reduce the risks to the health of workers, consumers, and the general public, and to minimize adverse effects on ecosystems and the envi ronment. Toxics use reduction falls under source reduction. Toxic chemical use substitutionrefers to the substitution of toxic chemicals with less harmful substances in products or processes. It can also include efforts to reduce or eliminate the use of specific chemicals or categories of toxic substances through development of appropriate substitutes or alternative technologies. Source reduction and toxic chemical use substitution together comprise industrial pollution prevention. (U.S. EPA, Pollution Prevention 1991: Progress on Reducing Industrial Pollutants. EPA 21p-3003. Washington: Office of Pollution Prevention, U.S. EPA, October, 1991. pp. 6-7.)

Return to the NPPC Homepage
last revised: September 5,1997.