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no effective means have been devised for storage, retrieval, and analysis of this

information. 2. Federal information on water quality is now

accessible to only two thirds of State governments and access by the scientific com

munity is limited. 3. Methods of water quality measurement lack

coherent network design, standardization and adequate data quality assurance procedures. Data collected by the U. S. Geological Survey are a notable exception.

infestations. (Pest infestation data are largely limited to USDA information on agricultural

pests.) 5. Pesticide producer registration data is re

ported on a company basis. No information is collected on location of establishments; therefore, information is lacking on where quantities of pesticides are produced and what exposure of the labor force is involved.

Toxic Substances

Air Quality

1. Standard methods of measurement and quality

assurance are inadequate, and the resulting

data are not comparable between cities. 2. Changes in meteorological factors which affect

the chemical composition and concentration of pollutants are not adequately accounted for in

monitoring air quality. 3. Data on the exposure of the population to air

pollutants is incomplete, because no information is collected on pollutants in the households. Data on workplace pollution exposure is limited, and some data on exposure to pollutants in the ambient air is of questionable validity and reliability. Consequently, the total exposure of individuals to specific pollutants and their

concentrations is not known. 4. Air quality data compiled by the Federal

Government is accessible only to EPA and
CEQ and to those agencies with difficulty.

The degree to which the collection and the analysis of environmental data is scattered among Federal departments and agencies is strikingly illustrated by the fact that more than 50 agencies either collect or analyze information on toxic substances. In April of 1977 these agencies maintained more than 200 chemical substance data bases and information systems. Of these 75 were controlled by the Department of Health, Education and Welfare, 39 by the Environmental Protection Agency, 18 by the Department of Commerce, and 14 by the Department of the Interior.

Federal government collection and analysis of information on chemical substances has been substantially modified by the enactment of the Toxic Substance Control Act (P. L. 94-469) which became effective January 1, 1977. The purpose of the act is to regulate chemical substances mixtures which present an unreasonable risk of injury to health or the environment. The Environmental Protection Agency has primary responsibility for carrying out the major provisions of this act. Authority is provided in the act for the collection of an extensive range of information including: trade names, chemical identity, molecular structure, categories of use, volume of production by use category, by-products, exposure of workers producing specific chemicals, methods of disposal, volume of imports, adverse reactions, health effects, environmental effects, quality control methods, and economic consequences of production or stopping production.

The act contains provisions explicitly addressed to the fragmentation of chemical substance data collection and analysis. For example, it requires (Sec. 10 (b)(1)) the Administrator of EPA to “establish, administer and be responsible for the continuing activities of an interagency committee which will design, establish and coordinate” a “system within the Environmental Protection Agency for the collection and dissemination to other Federal departments and agencies and use of data submitted to the Administrator under the Act.” The Act also provides for the Council on Environmental Quality

Pesticides

Information is lacking on how much technical grade product is being manufactured by whom and for incorporation in what particular final

products. 2. Air and water quality programs provide

information on the presence of pesticides, but do not provide adequate information on the

source or concentration of those substances. 3. Inventory data is lacking. There is no

information on how much of particular pesticides is being stored and where such

storage is located. 4. Information on the specific use of pesticides is

lacking, as well as related information on pest

to conduct a study on the feasibility of establishing a standard classification system for chemical substances and a standard means for storing and gaining rapid access to information on such substances.

Since implementation of the act in January of 1977 steps have been taken which address a significant need for interagency coordination in the planning and development of programs which collect and analyze chemical substance information. In May, the President's Environmental Message announced to Congress that he had directed “the Council on Environmental Quality to establish an interagency task force to review present environmental monitoring and data programs and to recommend improvements that make these programs effective.” In August, the Consumer Product Safety Commission, the Environmental Protection Agency, the Food and Drug Administration and the Occupational Safety and Health Administration announced the establishment of the Interagency Regulatory Liaison Group the purpose of which includes: development of compatible testing standards and guidelines; a common approach to assessing health risks of hazardous chemicals, development of coordinated information systems, and a collaborative review of research efforts.

Scores of information systems in many agencies collect, reference or manipulate chemical-related information and data. These employ a variety of identifiers and classification schemes which discourage coordination of data collection, its exchange and analysis. One of the tasks for the Interagency Toxic Substance Data Committee will be to address itself to identifying and evaluating the various ways in which chemicals and chemical information are identified and classified in such a system to facilitate data exchange and to eliminate duplicative efforts. This task will need to include the development of recommendations concerning the uniform use of the unique chemical identifiers, a standard system of chemical use classification, and means of converting from existing practices to uniform standards.

Many Federal agencies are involved in collecting or generating information on all aspects of chemical production, use, disposal and environmental effects. The information obtained is used for different purposes in various agencies. Nevertheless, many of the numerous requests to industries for information concern basically the same data. To minimize the reporting burden on industry, which will increase under the Toxic Substance Control Act, standardization and coordination of reporting, recordkeeping procedures and formats is required. One of the committee's objectives is investigating existing recordkeeping requirements and reporting procedures used by Federal agencies in dealing with chemical and chemical effects data for the purposes of devising a standard format or formats for reporting that information. Work on this objective is aided by an inventory of environmental information systems produced for CEQ.

Issues of confidentiality are among the most critical to be faced in the development of coordinated Federal collection and analysis of chemical substance information. Most of the Federal agencies which have responsibility for protecting the public health in the environment also have mandatory authority to collect data, test results, obtain business records and other information from industries. Such authority is essential for decisionmaking and enforcement on the part of those agencies. In order to protect private enterprise, Congress has, with some exceptions, totally forbidden disclosure of trade secrets.'

The basic framework for determining what information may be released by the agencies to the public or to other agencies is obtained by examining the Freedom of Information Act and 18 USC 1905.

In November of 1977 the Council on Environmental Quality established the Toxic Substances Strategy Committee. The general purpose of this committee is to serve as the principal forum for the development of Administration initiatives with respect to government-wide toxic substances strategy and policy. Included among the more specific objectives is to make recommendations on data collection, recordkeeping, reporting, and exchange of data and utilization of information and research results in regulatory and policy decisionmaking.

Another group was initiated in February of 1978 under the joint leadership of EPA and CEQ. This is the Interagency Toxic Substance Data Committee. This committee was established to carry out specific responsibilities given to EPA and CEQ in the Toxic Substance Control Act. The committee will concentrate on coordination of planning and activities of major Federal producers and users of chemical data to minimize reporting burden and facilitate the collection, analysis and exchang of data. The committee will determine the feasibility of establishing standard classifications and nonmenclature systems for chemical substances and study chemical information data bases and data needs.

'This interpretation has been challenged in Chrysler V. Schlesinger now scheduled for hearing before the Supreme Court in the fall of 1978.

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Superimposed over these statutes are qualifications emissions, and ambient conditions such as noise and and modifications prescribed by the various heat. Some standards relate to the work practices of substantive statutes which give the agencies their particular occupations; for example, power press regulatory authority. Although all of these statutes operators and carpenters (guarding of power prohibit to some extent the public disclosure of operated hand saws). Occupational illness and injury "trade secrets," none define the term either explicitly data are not collected on a statistical basis which can or in their legislative histories.

describe and analyze the relationships that exist

between injuries, illnesses, industry, occupation, Current laws and practices restricting release of

work experience, and workplace standards. This gap information by Federal agencies to other Federal

effects compliance program planning, priority setting agencies and to the public are not uniform. These

for development of workplace standards, and plans issues are addressed at length in other chapters of the

for research programs. Framework, particularly in the chapter on confidentiality. The Committee will need to address Lack of information on occupational illnesses is this issue in considerable depth to develop recom considered to be a major statistical gap by the mendations that will allow for protection of Occupational Safety and Health Administration. confidential data while also allowing optimal There are three statistical programs which could, but exchange and use of data.

do not, close that gap. First, it is believed that

occupational illnesses are seriously under-reported Economic Impact of Environmental Regulations on the BLS annual survey of Occupational Illnesses

and Injuries. Second, annual figures of the national Information on the economic impact of

Health Interview Survey (NCHS/HEW) of 40,000 environmental programs is needed for such purposes

households are often not of sufficient size to relate as estimating their importance in the household,

morbidity conditions to industry and occupation of business, and government sectors of the gross

the respondent. Aggregated data from the Health national product, their impact on investment outlays

Interview Survey will provide information for (actual and planned) of private industry, assessment

making broad determinations on the general of their impact on U.S. competition in foreign

occupational/morbidity relationships. The Social markets, and in determining their impact on

Security Administration's (SSA) administrative recemployment opportunities in the United States.

ords data on disabilities are available on the basis of a Measurement of the economic impact of

sample which is too small to meet Federal environmental programs requires information on

occupational safety and illness data requirements. In pollution abatement costs, transactions costs

addition, the SSA data provides information only on (planning, monitoring, enforcement), damages to the

cases where disability awards have been made. environment, and avoidance costs. While substantial information is available on abatement costs (Bureau Although spending for workers health and safety of Economic Analysis, Census and EPA), increases the direct cost of production and creates an information on transaction costs is less extensive. additional demand for capital investment, little Relatively little information is available to evaluate information is available on those costs. Such damages, and virtually nothing is collected on costs spending is now reported, but not separately of steps taken to avoid pollution. Thus, information identified, in the national economic accounts. This is incomplete or lacking on: (a) pollution abatement spending should be measured using definitions and related to plant closing and job losses, (b) the cost to concepts consistent with the economic accounts. industry and government entailed in the planning for, Such comparability is essential for comprehensive monitoring of, and enforcement of air, water, noise, analyses of the effects of occupational safety and and pesticides standards, (c) damages to human health regulations on the economy. Work on this health, plant and animal life, aesthetic values (public problem is included in the Bureau of Economic buildings, statues, etc.) and so forth, and (d) the Analysis' five-year plan of potential new projects. relative increase in the cost of production entailed by choices between different pollution

Future Directions control/abatement methods.

Concerns expressed by both environmental proOccupational Safety and Health

gram administrators and their statisticians indicate

that their perception of what data are needed has Occupational safety and health standards are changed. For example, there is current interest in the developed for workplace conditions, including validity and reliability of composite environmental substances, processes, equipment, and their indicators. The practice of developing vertical

Injury and Illnesses Causation

standards for specific industries may be supplemented or replaced by the development of horizontal standards for specific work practices, activities and processes. In addition the need to isolate the effects of exposure of persons to a particular pollutant in a particular setting from the more general exposure of the same persons to the same pollutant suggests the development of interagency integrated monitoring

There is also much to suggest that higher priorities are likely to be given to two areas of concern in the near future: (a) the identification of and collection of data on the population-at-risk to particular safety and health hazards, and (b) the identification and demonstration of cause and effect relationships.

Population-at-Risk Data

The programs of both EPA and OSHA are emerging from an initial emphasis upon broadly recognized hazards, established monitoring techniques, and recognized abatement and control methods. There are many hazards in the environment which are known to exist, but little is known with respect to the numbers of persons exposed, their degree of exposure or the effects of those exposures. For example, there is no information on the number of workers engaged in producing pesticides, the degree of their exposure to those products or the secondary exposure of family members through transport of chemicals from workplace to the home on the clothing of workers. The same lack of information exists with respect to many thousands of chemical substances which are known to be toxic.

Historically, efforts to record and collect data on the causes of occupational injuries have been influenced by concern for establishing legal responsibility. This is still largely the case. Federal agencies now recognize that identification of legal responsibility differs from the detailed specification of a causal chain required for the development of strategies calculated to remove or reduce risk for a target population. The development of these strategies and promulgation of relevant standards are the driving forces behind a concerted new emphasis upon human health effects studies and research directed toward identifying the kinds of information required for worker injury analysis.

This chapter describes the collection of environmental statistics as characterized by an evolutionary process. Currently, it has attained that point in its development which requires direction of serious attention to assessments such as the following contained in the National Research Council 1977 report Environmental Monitoring.?

EPA does not adequately apply scientific principles to the design, operation, and evaluation of monitoring programs. Programs are too often developed hastily in response to the dictates of legislation and enforcement procedures and the exigencies of pollution control management, instead of being based on clear objectives, priorities, and criteria related to a National monitoring system. As a result, current monitoring does not adequately serve the important purposes of evaluating the progress of national environmental programs in terms of changes in environmental quality and determining relationships among sources of pollution; ambient environmental quality; and affects on humans,

animals, and plants. This report of the National Research Council elsewhere states:

If it is to make informed decisions, EPA should analyze the data it requires. It appears, however, that most of these data are not analyzed adequately. Since data collection is expensive the EPA should determine that data not only meet their intended purposes efficiently, but that they serve as many purposes as possible. The Agency should analyze its environmental data in relationship to various purposes they could serve,

A somewhat analogous situation exists in regard to occupational injuries. Though reliable data exists concerning the number of injured workers classified by industry and by State, there is inadequate information on occupation of injured, work history of injured, part of body injured, and events occurring at the time of injury. These kinds of data are not available on the injured population and are required for the development of information on the cause or causes of injuries.

Information identifying the population-at-risk from particular hazards is deemed essential for establishing priorities for new standards and thereby priorities for research. Otherwise, the priorities of environmental programs are forced to respond to reports of major catastrophies and appearances of high risk in spite of evidence which indicates that yesterday's tragic event is no predictor of tomorrow's trauma.

?National Research Council, Environmental Monitoring, a report to the U.S. Environmental Protection Agency from the Study Group on Environmental Monitoring (Washington, D.C., National Academy of Science, 1977), pp. 5-6.

such as evaluating national monitoring networks, measuring the progress of environmental programs and studying relationships between pollution and its effects. In addition, EPA should summarize its data in more informative annual reports and disseminate data earlier and more widely to others who would find them helpful. EPA research reports, at least those that might have a major impact on public policy, should undergo stern scientific review, and some should be submitted to refereed journals. The agency should also publish the scientific and economic analyses upon which its decisions are based.

that can be taken to improve the effectiveness

and efficiency of such programs; 3. Recommending new Federal programs or

mechanisms as needed to accomplish these

objectives; and 4. Developing options, estimating costs, making

recommendations, and offering justifications

for potential Executive actions. The Task Force has formed working groups to concentrate on air pollution, water, ecological and living resources, natural resources and land use and socioeconomic data and monitoring. Analyses, findings and recommendations are expected to be included in a series of reports throughout 1978 and 1979.

The problems with EPA's management of scientific data are exacerbated by the paucity of statistical talent in the Agency. In addition to producing and consuming data about the environment, EPA has many statistical responsibilities. For example, the Agency writes environmental guidelines and standards that must take account of natural variability, and it specifies statistical measures in regulations that must be designed for efficient enforcement. Statisticians are needed to cooperate with other scientists in improving the design of experiments and surveys and improving techniques for sampling, data analysis, quality assurance, and decision making under uncertainty. It should be noted at this point that in the spring of 1978, EPA began to establish a small statistical office to begin to address these problems.

The purpose of this chapter has been to portray the scope and complexity of Federal collection and analysis of environmental and work place statistics. It has sought neither to describe these activities in detail nor to provide a critique of the many statistical issues which characterize those data. So brief a summary should not be misread, for the issues identified are illustrative and do not exhaust the range of significant concerns which must be addressed. Although this chapter's description of environmental data collection is intended to be illustrative and summary in character, its recommendations are more comprehensive. They are primarily addressed to management functions rather than statistical issues.

Required Coordination Mechanism

There has been a great need for a more coherent view of the Federal need for and production of environmental statistics. Moreover, some agencies which have primary environmental missions do not have a systematic view of their data needs and statistical resources.

The further development and improvement of Federal statistics on the environment should be facilitated by the establishment of the Interagency Task Force on Environmental Data and Monitoring. This task force will perform its charge through several activities to make environmental data and monitoring programs more effective. These include: 1. Identifying and documenting the most im

portant problems, deficiencies, and needs of environmental data and monitoring programs that are conducted, supported, or used by

Federal agencies; 2. Analyzing the pertinent issues, developing

findings, and recommending paths of action

The need to review statistical programs in the light of the program administrator's experience is illustrated by the serious questions now being raised in regard to the global appetities for data associated with environmental impact statements. Environmental impact statements must be prepared by Federal agencies when actions on their part will have significant impact upon the environment. Such actions include awarding of construction grants for the building of dams and sewers and the issuance of permits to industry to discharge pollutants into navigable streams. Between 1970 and 1975 Federal agencies developed nearly 7,000 draft environmental impact statements. In many instances the drafting of these statements results in the agency imposing a significant reporting burden on the public. The scale of this reporting requirement and the fact that considerable variation exists between agencies in regard to the nature of those requirements has become an important issue. As a consequence the Council on Environmental Quality has been directed to assume responsibility for the development of Federal regulations which will standardize these requirements.

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