ATURES

Strategies for Eliminating and ReducingPersistent Bioaccumulative Toxic Substances:

Common Approaches^ Emerging Trendŝand Eevel of Success

Kate Davies, M.A., D.Phil.

Abstract This paper reviews nine of the best-known strategies foreliminating and reducing substances in the category knownas "persistent hioaccumulative toxic substances" (PBTSs). The nine strategies are as fol-lows: 1) Ontario's CanAikte Substances list for Bans and Phose-outs (1992), 2) Canada'sARET Program (1994), 3) Canada's Toxic Substances Management Policy (1995), 4) theCommission for Environmental Cooperation's Sound Management of Chemicals Initiative(1995), 5) the Great Lakes Binational Toxics Strategy (1997), 6) the U.S. EnvironmentalProtection Agency's (U.S. EPA's) draft National PBT Strategy (1998), 7) U.S. l?Xs WasteMinimization Program (1998), 8) the U.N. Stockholm Convention on Persistent OrganicPollutants (2001), and 9) Washington State's Rule on Persistent Bioaccumulative Toxins(2006). The review describes the commonalities among the strategies, including their goalsand principles, design approaches, and other common elements. It also discusses severalemerging trends, such as the increasing importance of economic considerations, humanhealth information, and nonregulatory management approaches. The paper concludeswith a discussion of how effective the strategies have been at achieving their goals ofelimination and reduction of persistent bioaccumulative toxic substances.

IntroductionOver the past 13 years, government organi-zations in North America and internation-ally have developed strategies to eliminateand reduce the production, use, and releaseof persistent bioaccumulative toxic sub-stances (PBTSs) in response to the mount-ing scientific evidence that toxic substancesof this type pose greater risks to humanhealth and the environment than do others.These unique risks result from the propen-sity of PBTSs to remain in the environment

for a long time without breaking down;their potential to bioaccumulate in human,animal, or fish tissues; and their toxicity. Asa result of their characteristics, PBTSs oftenmigrate from one environmental medium toanother and travel thousands of miles vialong-range atmospheric transport to regionsfar from where they originally entered theenvironment. Moreover, many species, es-pecially top predators, can experience long-term cumulative exposures to PBTSs overtheir entire lifetimes.

The unique risks posed by PBTSs werefirst acknowledged by the governments ofthe United States and Canada in the GreatLakes Water Quality Agreement (1978),which stated; "The discharge of any or allpersistent toxic substances (should) be vir-tually eliminated" (International Joint Com-mission United States and Canada, 1989).Nearly all persistent substances have thepotential to bioaccumulate.

PBTSs include some pesticides, such asaldrin; some chemicals used in commerce,such as PCBs; some products of incompletecombustion, such as dioxins and furans; andsome heavy metals, such as mercury, lead,and cadmium.

This article reviews nine strategies foreliminating and reducing PBTSs, startingwith the earliest and concluding with pos-sibly the most recent. Although there aremany other strategies for managing toxicchemicals in general, as well as for managingindividual PBTSs, the ones reviewed here arethe nine best-known strategies for managingPBTSs as a category.

Snmmary of Strategies

Ontario's Candidate Substances List forBans and Phaseouts (1992)In 1992, tbe Ontario Ministry of tbe Environ-ment published its Candidate Substances List forBans and Phase-outs (Socha et al., 1992), partlyin response to the commitment of tbe GreatLakes Water Quality Agreement to virtualelimination. Tbe list identifies 27 substances.

December 2006 • Journal of Environmental Health

To develop the list, the ministry assessed thepersistence, bioaccumulative potential, and tox-icity of approximately 800 substances known tobe present in the Great Lakes basin. The Candi-date Substances Listjor Bans and Phase-outs didnot lead directly to the ban or phaseout of anysubstances, although it served as an importantprecedent for subsequent strategies for eliminat-ing and reducing PBTSs.

Canada's ARET Program (1994)The multi-stakeholder Accelei-ated Reduc-tion/Elimination of Toxics (ARET) Programdeveloped a list of 117 PBTSs based on anevaluation of over 2,000 substances (En-vironment Canada, 2003). In 1994, ARETissued a voluntary challenge to Canadianindustry to virtually eliminate releases of 30PBTSs on the list and to reduce releases ofthe other 87 suhstances to levels insufficientto cause harm. ARET also issued two short-term goals: To reduce emissions of PBTSs by90 percent and all other emissions of toxicsubstances by 50 percent by 2000. ARETwas judged to be successful by the Cana-dian government, which stated: "The ARETchallenge proved to be very successful. Bythe year 2000 ARET succeeded in attractingparticipation from 8 major industry sectors,171 companies and government organiza-tions, and 318 individual facilities. Collec-tively, these participants achieved a totalreduction in releases to the environment ofalmost 28,000 tonnes" (Environment Cana-da, 2003). One review of ARET found, how-ever, that reported emission reductions hadlargely resulted from an econoriiic downturnthat had led to decreased industrial activity,rather than from the program itself (Envi-ronment Canada, 2000).

Canada's Toxic Substances ManagementPoticy (1995)Canada's Toxic Substances ManagementPolicy (TSMP) contains two managementobjectives (Government of Canada, Environ-ment Canada, 1995a): 1) virtual eliminationfrom the environment of toxic substancesthat result predominantly from human activ-ity and that are persistent and bioaccumtila-tive (referred to as Track 1 substances) and2) management of other toxic substancesand substances of concern throughout theirentire hfecycles (referred to as Track 2 sub-stances). The policy contains specific criteriafor persistence and bioaccumulation (Gov-ernment of Canada, Environment Canada,1995b). Toxicity is assessed using procedures

oudined in the Canadian Environmental Pro-tection Act, which also contains provisions toimplement the poUcy

The Toxic Substances Management Policywas reviewed in 1999 by the federal Com-missioner of the Environment and Sustain-able Development as part of a larger audit ofhow the Canadian government was manag-ing the risks from toxic substances. In herreview, the commissioner commented: "TheToxic Suhstances Management Pohcy ... isnot being fully implemented, nor is there agovernment-wide plan to do so. Strategiesfor the management of specific substances,although required by the policy, have notbeen developed or implemented. Estab-lished government objectives are not beingachieved" (Commissioner of the Environ-ment and Sustainable Development, 1999, §4.140). She added: "The current programsare insufficient to ensure that risks will beadequately addressed in the future. Sub-stance-specific objectives for the protectionof human health and the environment havenot been adequately defined, and agreed re-ductions in the release of toxic substancesare not assured" (Commissioner of the En-vironment and Sustainable Developinent,1999, §4.141).

The Sound Management of ChemicalsInitiative (1995)In 1995, the Commission for Environmen-tal Cooperation of North America passed aresolution to improve the management ofchemicals, giving priority to persistent, toxicsubstances of mutual concern to the UnitedStates, Canada, and Mexico (Commission forEnvironmental Cooperation of North Ameri-ca, 2003). To accomplish this, the resolutioncalled for the development of North Ameri-can regional action plans (NARAPs). To date,plans for six specific substances have beendeveloped (DDT, chlordane, PCBs, mercury,dioxins/furans, and hexachlorobenzene).

In the future, the Sound Management ofChemicals Initiative plans to emphasize im-plementation of the existing plans; reportingon emerging issues of concern; building part-nerships and capacity; improving biomoni-toring and environmental monitoring; andpublic involvement, communications, andoutreach (North American Working Groupon the Sound Management of Chemicals,2004). Thus, it is unlikely that many moresubstance-specific North American regionalaction plans will be developed.

Great Lakes Binational Toxics Strategy(1997)The Great Lakes Binational Toxics Strat-egy (U.S. Environmental Protection Agency[U.S. EPA], 1997) is based on the commit-ment to virtual elimination of certain tox-ics made by the Great Lakes Water Qual-ity Agreement of 1978 (International JointCommission United States and Canada,1989). The strategy identifies 12 "Level 1"substances as the primary focus for U.S. andCanadian government actions. These sub-stances have been targeted for virtual elimi-nation because of their actual or potentialenvironmental effects and their presence inthe Great Lakes basin. The strategy containsspecific U.S. and Canadian "challenges" forindividual Level 1 substances. The strategyalso identifies 14 "Level 2" substances thatare subject to pollution prevention activi-ties. These suhstances were selected becausethey have the potential to significantly affectthe Great Lakes ecosystem.

In 2001, the Internatioiial Joint Commis-sion i'eviewed the Great Lakes BinationalToxics Strategy (International Joint Com-mission, 2001). The review focused on theLevel 1 substances and concluded that thestrategy had achieved its purpose of set-ting forth a "collaborative process by whichEnvironment Canada (EC) and the UnitedStates Environmental Protection Agency ...,in consultation with other federal depart-ments and agencies, Gireat Lakes states, theProvince of Ontario, Tribes, and Eirst Na-tions, will work in cooperation with theirpublic and private partners toward the goalof virtual elimination of persistent toxicsubstances resulting from human activ-ity, particularly those which bioaccumulate,from the Great Lakes Basiri, so as to protectand ensure the health and integrity of theGreat Lakes ecosystem" (U.S. EPA, 1997).The review went on to state, however, that"many of the reductions made in releases ofLevel I substances cannot be attributed tothe Strategy unequivocally" (InternationalJoint Commission, 2001).

U.S. EPA's National PBT Strategy:Working Draft (1998)The U.S. EPA draft National PBT Strategy(U.S. EPA, 1998) focuses on the same 12 Level1 substances addressed by the Great Lakes Bi-national Toxics Strategy, and it proposes to de-velop a national action plan for each one. Onlyone plan has been finalized (for alkyl lead),and the strategy has never been finalized.

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U.S. EPA's Waste Minimization Program(1998)The Waste Minimization Program seeks toreduce or eliminate waste in manufacturingby focusing on 31 priority chemicals tbat aretracked through the Toxics Release Inven-tory Specifically, the program's goals includethe "complete elimination of, or substitutionfor, priority cbemicals, wherever possible"(U.S. EPA, 2005a). The principal vehicle forachievitig the program's goals is the NationalPartnership for Environmental Priorities,wbicb encourages public and private organi-zations to form voluntary partnerships withU.S. EPA to reduce the use or release of anyof 31 priority chemicals. Tbe goal is to reducethe amount of priority chemicals reported totbe Toxics Release Inventory by 10 percent by2008, with tbe year 2001 taken as a baseline.

U.S. EPA developed tbe Waste Minimiza-tion Prioritization Tool, partly to supportthe Waste Minimization Program (Notice ofAvailability of Waste Minimization Softwareand Documents, 1997). Tbe tool is a softwarepackage that ranks substances according totbeir persistence, bioaccumulative potential,and toxicity.

U.N. Stockholm Convention on PersistentOrganic Pollutants (2001)Tbe U.N. Stockbolm Convention on Persis-tent Organic Pollutants requires tbe elimi-nation or reduction of 12 persistent organicpollutants (United Nations EnvironmentProgramme, 2001). It also contains a pro-cess for adding new cbemicals and a financ-ing mecbanism to belp developing countriesand countries witb economies in transitionto meet tbe obligations of tbe agreement.The convention entered into force in 2004,after it had been signed and ratified by 50countries. At present, 114 countries haveratified the convention. Tbey do not includetbe United States, which bas signed but notratified the convention.

Washington State's PBT Rule (2006)In 2006, Washington State adopted a rule onPBTSs, making Wasbington tbe first state tohave a regulatory strategy to manage PBTSsas a category of substance. Several otberstates bave strategies for individual PBTSs,but no other state bas a strategy for PBTSsas a group.

Washington's rule consists of a two-stepprocess, comprising a procedure for selectinga list of PBTSs, and tben one to select whichPBTSs on the list will have "chemical action

plans" prepared for them. Tbe rule (Washing-ton Department of Ecology, 2006) comprisescriteria for persistence, bioaccumulation, andtoxicity, an initial list of PBTSs based on tbecriteria, a procedure for updating the list, cri-teria for selecting PBTSs for which chemicalaction plans will be prepared, and guidanceon the scope of chemical action plans.

Commonalities Among theStrategiesGoalsAll of the strategies considered in this reviewhave the ultimate goal of eliminating or ban-ning tbe use, production, release, or disposalof the most bazardous PBTSs, as well as of re-ducing releases of otbers. The precise mean-ing of tbe word elimination can, however, beproblematic because advances in analyticalcbemistry are permitting tbe measurement ofever-decreasing concentrations of substances.Tbe Canadian Environmental Protection Actof 1999, wbicb provides the legal autborityfor tbe Toxic Substances Management Poli-cy, deals witb tbis issue by defining "virtualelimination" as "tbe ultimate reduction of tbequantity or concentration of tbe substance inthe release below the level of quantification"(Department of Justice Canada, 1999). Otberstrategies, sucb as Washington State's PBTRule, do not define elimination, and theydeal witb this issue on a substance-by-sub-stance basis.

PrinciplesSeveral of the strategies refer to the need forprecautionary action, including tbe ToxicSubstances Management Policy, tbe SoundManagement of Chemicals Initiative, and tbeStockholm Convention. The essence of theprecautionary approach is that it is often nec-essary to take action on environmental healthissues without complete scientific informa-tion on the risks. There are various ways ofarticulating the precautionary approach, butperhaps the best-known is Principle 15 of tbeRio Declaration, which states tbat "wheretbere are threats of serious or irreversibledamage, lack of full scientific certainty sballnot be used as a reason for postponing cost-effective measures to prevent environmentaldegradation" (U.N. Environment Programme,1992). None of the U.S. strategies mentionthe need for a precautionary approach.

A second common principle is the lifecycleor cradle-to-grave approach. Tbis refers tothe management of PBTSs from manufacture

and production through use and ultimatedisposal. For example, the Toxic Substanc-es Management Policy contains a sectionon lifecycle management (Government ofCanada, Environment Canada, 1995a) thatlinks tbis principle witb pollution prevention(discussed below). Similarly, in its resolution95-05, tbe Commission for EnvironmentalCooperation of Nortb America states tbat itsSound Management of Cbemicals Initiativerecognizes "the need to assess and developstrategies for addressing new and existingchemicals in North America, throughouttheir life cycles" (2003, p. 19). The WasteMinimization Program takes this principlea step further and promotes cradle-to-cradlemanagement that emphasizes closed-loopmanagement systems and recycling wheneverelimination or minimization are not possible(U.S. EPA, 2004).

Pollution prevention is a tbird principlecommon to several of tbe strategies. Pollu-tion prevention bas been defined as follows:"Tbe reduction or elimination of pollution attbe source (source reduction) instead of at tbeend-of-tbe-pipe or stack" (National PollutionPrevention Roundtable, n.d.). Eor example,tbe Toxic Substances Management Policystates tbat "pollution prevention is often tbemost cost-effective management strategy andin such cases will be promoted" (Governmentof Canada, Environment, 1995a, pp. 6-7). Incontrast, in its resolution 95-05, the Commis-sion for Environmental Cooperation of NorthAmerica simply states that "the prevention ofpollution ... is botb desirable and imperativein order to protect and improve the environ-ment of Nortb America" (2003, p. 20).

Design ApproachTbe environmental mobility of PBTSs posesa unique management challenge becauseit means tbat tbey can cross programmatic,institutional, and jurisdictional boundarieswitb ease. Tbus, strategies intended to man-age PBTSs in a single environmental mediumare likely to have limited success. Similarly,policies or legislation implemented by a sin-gle institution or jurisdiction are unlikely tomanage PBTSs comprebensively

Tbus, a key design consideration in all oftbe strategies is the need for cross-program,multimedia approaches to PBTSs. This needis most clearly articulated in U.S. EPAs draftnational PBT strategy wbicb states tbat "EPAis committing, through this strategy, to createan enduring cross-office system tbat will ad-dress tbe cross-media issues associated witb

Decemher 2006 • Journal of Environmental Health 11

[BLE 1Common Elements in Strategies for Eliminating and Reducing Persistent Bioaccumulative Toxic Substances (PBTSs)

Name of Strategy Common Elements

Ontario's Candidate Substances List for Bans and Phaseouts (1992)Canada's ARET Program (1994)Canada's Toxic Substances Management Policy (1995)Commission for Environmental Cooperation's Sound Managementof Chemicals Initiative (1995)Great Lakes Binational Toxiu Strategy (1997)U.S. EPA's draft National PBT Strategy (1998)U.S. EPA's Waste Minimization Program (1998)U.N.Stockholm Convention on Persistent Organic Pollutants (2001)Washington State PBT Rule (2006)

Criteria forPersistence,

Bioaccumulation,and Toxicity

YesYesYes

Yes

NoNoYesNoYes

Initial Listof PBTSs

YesYesNo

Yes

YesYesYesYesYes

ManagementObjectives

for IndividualSubstances on

Initial ListNoNoNo

No

YesYesNoYesNo

A Process forAdding NewSubstances

NoNoYes

Yes

NoNoYesYesYes

priority PBT pollutants" (U.S. EPA, 1998, p. iv).Similarly, the Stockbolm Convention is basedon tbe recognition tbat an international ap-proacb is necessary for controlling tbe trans-boundary movement of PBTSs.

Common ElementsTo acbieve their goals of elimination and re-duction, all of the strategies comprise two ormore of tbe following four elements: criteriafor persistence, bioaccumulation, and toxic-ity used to develop an initial list of PBTSs;an initial list of PBTSs; management objec-tives for individual PBTSs on tbe initial list;and a process for adding new substances totbe initial list of PBTSs. Table 1 gives a com-parison of tbese common elements in tbenine strategies.

Criteria for Persistence, Bioaccumulation,and ToxicitySix of tbe strategies contain pbysico-chemical criteria for persistence, bioaccu-mulation, and toxicity, including Ontario'sCandidate Substances List, ARET, tbe ToxicSubstances Management Policy, tbe SoundManagement of Cbemicals Initiative, theWaste Minimization Program, and Wash-ington State's PBT Rule. The most commonway of determining persistence is to con-sider tbe balf-life of tbe substance in tbeenvironment. A balf-life can be defined astbe time taken for balf of a substance todegrade or be transformed in tbe environ-ment. Half-lives can be measured in vari-

ous environmental media, including soil,water, and sediments. Tbey vary dependingon tbe medium, tbe specific degradationprocess studied, and site-specific condi-tions such as climate. Tbe Toxic SubstancesManagement Policy (Department of JusticeCanada, 1999) and tbe Sound Manage-ment of Cbemicals Initiative (Commissionfor Environmental Cooperation of NorthAmerica, 2003) allow substances to be cat-egorized as persistent if tbere is evidenceof atmospberic transport to remote regionssucb as tbe Arctic.

The strategies determine bioaccumula-tion potential using one or more of tbreemeasures: tbe bioaccumulation factor(BAE), tbe bioconcentration factor (BCF),and tbe log of tbe octanol-water partition(log Kow). BAEs and BCEs are more biologi-cally relevant because tbey take account tbemetabolism of an organism, whereas tbe logKow is a cbemical measure only. BCEs arelaboratory measures of tbe cbange in con-centration of a substance from the environ-ment into tissues, and BAEs are field mea-sures tbat take account of actual availabilityin tbe environment. In brief, tbe log Kow istbe most reproducible but tbe least similarto real-life field conditions, and tbe BAE isthe least reproducible but tbe most similarto field conditions.

All five strategies measure toxicity in termsof acute and chronic toxicity, as well as car-cinogenicity or teratogenicity. Some use scor-ing systems for toxicity that contain assump-

tions and values about tbe relevant impor-tance of different types of bealtb effects. Tbemost complex scoring system is probablytbe Waste Minimization Prioritization Tool(Notice of Availability of Waste MinimizationSoftware and Documents, 1997).

Initial Lists of PBTSsEigbt of tbe strategies have an initial list orlists of PBTSs for action. Tbese lists varyin lengtb from four substances (tbe SoundManagement of Cbemicals Initiative) to 87substances (ARET). Tbere is a bigb degree ofoverlap in tbe substances listed in differentstrategies.

Management Ohjectives for IndividualSubstances on the Initial List(s)Of tbe eigbt strategies witb an initial list orlists of PBTSs for action, tbree provide man-agement objectives for tbe individual listedsubstances (tbe Great Lakes Binational Tox-ics Strategy U.S. EPAs draft National PBTStrategy and tbe Stockbolm Convention).Eor example, tbe Great Lakes Binational Tox-ics Strategy contains specific managementobjectives for the U.S. and Canadian govern-ments for each of its Level 1 substances.

A Process for Adding New SubstancesEive of tbe strategies contain a specific pro-cess for adding new substances to the ini-tial list (tbe Toxic Substances ManagementPolicy, tbe Sound Management of CbemicalsInitiative, the Waste Minimization Program,

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the Stockholm Convention, and Washing-ton State's PBT Rule). These processes varyin terms of their lengtb and complexity, butall require that candidate substances meetthe criteria for persistence, bioaccumula-tion, and toxicity.

Emerging Trends

EconomicsTbe role of economics bas become moreprominent in tbe strategies over time. Eco-nomic factors were not mentioned in tbefirst two strategies (Ontario's Candidate Sub-stances List and ARET). The Toxic Substanc-es Maiiagement Policy states tbat; "whilesocio-economic factors haye no bearing onsetting tbe ultimate objective for a Track 1substance—its virtual elimination frotti theenvironment—such factors will be takeninto account when determining and imple-menting risk management measures undertbis policy. Eor example, tbey will belp todetermine interim targets, appropriate man-agement strategies and time lines" (Gov-ernment of Canada, Enviroiiment Canada,1995a, p. 9). All subsequent strategies baveincluded economics as a factor to be consid-ered in decisions about tbe elimination andreduction of PBTSs.

To date, the economic factors consideredin decisions have focused on the costs ofeliminating and reducing PBTSs. The societalcosts of tbe continued use of PBTSs, or tbeeconomic benefit:S of eliminating .or reduc-ing tbem; are not generally considered. TbeWaste Minimization Program recognizes tbisconsideration, asking: "Wbat are the truecosts to society of toxicants that eventuallyfind their way into tbe tissues of plants, ani-mals, and people?" (U.S. EPA, 2005a). Someresearcbers are now beginning to answer tbisquestion by estimating tbe economic costs as-sociated witb tbe bealtb and related effects ofPBTSs (Landrigan, Scbechter, Lipton, Eahs,& Schwartz, 2002; Trasande, Landrigan, &Schecter, 2005). The inclusion of informationon botb tbe costs of eliminating and reducingPBTSs and tbe costs of their continued usecould facilitate decisions about the elimina-tion and reduction of PBTSs.

Health InformationIn recent years, tbe role of bealth informa-tion in the identification of substances asPBTSs has increased in two ways. Eirst, abroader range of bealtb effects are being in-cluded in the toxicity criteria. For example.

tbe toxicity criteria given in Ontario's Candi-date Substances List refer only to acute andcbronic/subcbronic toxicity, carcinogenicity,and teratogenicity, wbereas tbe more recentWasbington State PBT Rule refers to car-cinogens, developmental and reproductivetoxicants, neurotoxicants, and acute andcbronic toxicity (Washington Departmentof Ecology, 2006). This change probably basoccurred because it is becoming clear tbatPBTSs are associated witb a wide diversityof bealth effects. Second, it is likely that theincreasing availability of epidemiologicalstuclies and tbe current policy climate in tbeUnited States are leading to a greater empha-sis on studies tbat detnonstrate actual effectsin human populations.

FeasibilityTbe early strategies called for tbe elimina-tion and reduction of PBTSs, witbout con-sidering wbether tbese goals were feasibleor practical. Ontario's Candidate SubstancesList, ARET, and tbe Toxic Substances Man-agement Policy do not mention tbe t;echno-logical feasibility of elimination and reduc-tion, or tbe availability of alternatives orsubstitutes. Tbe idea that feasibility sbouldinfluence tbe goals of elimination and re-duction came later, in tbe Sound Manage-ment of Cbemicals Initiative, wbicb statesthat the "availability of alternatives" is oneof the considerations in nominating a sub-siance for action (North American Com-mission for Environmental Cooperation,1997). The feasibility of elimination andreduction bas beeri included in all subse-quent strategies.

Nonregulatory ApproachesOver tbe years, tbere bas been a trend to-ward nonregulatory environmental man-agement approacbes, including tbe use ofvoluntary, economic, and incentive-basedinstruments (Press & Mazmanian, 2006).Tbis trend bas also held for PBTS strate-gies. Two of tbe early strategies, Ontario'sCandidate Substances List and tbe ToxicSubstances Management Policy, empba-sized regulatory or command-and-controlapproacbes. In contrast, tbe more recentstrategies emphasize either voluntary ap-proaches, as in tbe Waste MinimizationProgram, or blended approacbes, as inWashington State's PBT Rule. None of tbeinternational strategies contain bitidingregulatory measures because of tbe need tosafeguard national sovereignty.

The Snccess of Strategiesfor Redncing PBTSsHave tbe strategies acbieved tbeir goals ofeliminating and reducing PBTSs in tbe en-vironnient? Unfortunately, tbe answer is notat all clear. Tbere are several reasons. Eirst,tbe monitoring information on levels in tbeenvironment of most of tbe listed PBTSs isinsufficient to establisb convincing tempo-ral trends for tbe geograpbic regions cov-ered by tbe strategies. Eor example, only afew of tbe PBTSs listed in tbe strategies aresubject to reporting under tbe Toxics Re-lease Inventory, and these data do not showany clear trends over time. In some years,reported releases of PBTSs have increased,and in otbers they have decreased. Datafrom 2000-2001 show a decrease of about2 percent (U.S. EPA, 2003), while data from2001-2002 and 2002-2003 show increasesof 3 percent (U.S. EPA, 2004) and 11 per-cent (U.S. EPA, 2005b), respectively

Moreover, it is virtually impossible to tracktbe effectiveness of the individual strategiesbecause only one (ARET) bas a mecbanismfor reporting reductions in emissions. Noneof the otber strategies contain a mecbanismfor monitoring environmental outcomes.Tbe need to measure success in terms of en-vironmental results is recognized in tbe draftnational PBT strategy, wbicb states: "EPAwill measure progress on actions under tbisstrategy tbrougb: (1) environmental or bu-man bealtb indicators, (2) cbemical release,waste generation, or use indicators" (U.S.EPA, 1998, p. 11). Tbis measurement doesnot appear to bave occurred, bowever.

A second reason tbat it is difficult to makedefinitive statements about tbe success of tbestrategies is tbat many of tbe substances ontbe initial lists of PBTSs were already bannedor controlled before tbe strategies were devel-oped. Eor example, all 12 PBTSs identifiedby 1999 as persistent, bioaccumulative, andtoxic uiider tbe Toxic Substances ManagementPolicy were subject to bans or managementcontrols before tbe introduction of the policyin 1995. Eigbt were pesticides tbat bad beenbanned in Canada for many years, and an-otber was PCBs, wbose use has been restrictedsince 1980. The other tbree substances—di-oxins, furans, and bexacblorobenzene—weresubject to stringent control actions before tbeimplementation of tbe policy in 1995 (Com-missioner of tbe Environment and SustainableDevelopment, 1999). This circumstance is truefor otber strategies as well. Tbus, tbe strategiesthemselves probably bad httle effect on many

Decemher 2006 • lournal of Environmental Health 15

of the listed PBTSs because tbose substancesbad already been banned or controlled.

Tbird, implementation of several strategiesbas been extremely slow, or bas not taken place.Eor example, Ontario's Candidate SubstancesList did not lead directly to any bans or pbase-outs. In its 10-year life, the Sound Managementof Chemicals Initiative has developed NorthAmerican regional action plans for six sub-stances. In otber cases, most notably the Stock-bolm Convention and Wasbington State's PBTRule, it is too early to evaluate tbeir success.

Eourtb, any reductions in environmental lev-els of PBTSs may be due to a variety of factors.As noted above, many of tbe PBTSs on tbe ini-tial lists had already been banned or controlled,and tbese measures may bave resulted in re-duced levels. Otber factors tbat are likely to berelevant include economic considerations. Eorexample, a review of ARET found tbat reportedemission reductions were largely a result ofan economic downturn tbat led to decreasedindustrial activity, ratber tban to ARET itself(Environment Canada, 2000). Tbis findingsuggests tbat economic trends are likely to sig-nificantly influence emissions of PBTSs.

Conclnding ThoughtsIt is clear tbat there are many similaritiesamong the PBTS strategies tbat bave beendeveloped over tbe past 14 years, and tbattbere are also several emerging trends. It isunclear, bowever, wbetber collectively tbeyhave been successful in achieving their goalsof elimination and reduction of PBTSs in tbeenvironment.

Despite tbis uncertainty, tbey bave drawnattention to the issue of PBTSs in many dif-ferent sectors of society. Policy makers arenow much more aware of the need to man-age these substances tbrough governmentpolicies and programs, and one strategybas led to anotber. Similarly, tbe public isbecoming more aware of tbe bealtb bazardsassociated witb PBTSs, and some peopleare now limiting tbeir exposures tbrougbpersonal lifestyle choices. Industry is in-creasingly cognizant of tbe need to elimi-nate and reduce PBTSs. Eor example, par-ticipation in Responsible Care®, an inter-national program wbose purpose is to ad-vance the safe and secure management ofchemical products and processes, is now

mandatory for all members of tbe Ameri-can Cbemistry Council (American Cbemis-try Council, 2005). Also, researcbers arenow studying the health and environmen-tal effects of PBTSs with a depth andbreadtb tbat were unimaginable 15 yearsago. Tbe increase in researcb bas led toknowledge of tbe endocrine-disrupting po-tential of many PBTSs, among other infor-mation. Although it is unclear that tbestrategies bave been successful at eliminat-ing and reducing PBTSs, tbey bave beenvery effective in raising awareness. Jf

Acknowledgement: Tbe author would like totbank tbe Seattle Biotecb Legacy Eoundationfor financially supporting tbis study

Corresponding Author. Kate Davies, CoreFaculty Environment & Community, andAssociate Director, Antiocb University-Se-attle, Center for Creative Cbange, 2326 SixtbAvenue, Seattle, WA 98121-1814. E-mail:kdavies@antiocbseattle.edu.

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