EPA Reorganizes OPPT
Bergeson Campbell P.C. - Washington Office
|June 5, 2014|
The U.S. Environmental Protection Agency (EPA) Office of Pollution Prevention and Toxics (OPPT) recently noted that it successfully completed the Agency's reorganization process and that the effective date will be sometime after June 9, 2014. The reorganization, which Bergeson & Campbell, P.C. (B&C®) had discussed in its "Predictions" memo, available online, represents a significant shuffle in responsibilities and also reduces the number of OPPT Divisions by one with the elimination of the Pollution Prevention Division (PPD). The new organizational chart can be accessed online. According to OPPT management, the changes are intended to:
- Help position OPPT to better address current and future challenges;
- Address the increased importance of producing risk assessments by consolidating risk assessment components; and
- Promote better coordination of pollution prevention efforts, including promoting the use of safer chemicals.
OPPT notes that the reorganization also does not eliminate any of its current functions, nor will it alter the employment status of any current OPPT staff.
Whereas OPPT had previously been structured with human and environmental hazard and risk assessment in the Risk Assessment Division (RAD) and exposure assessment in the Economics, Exposure, and Technology Division (EETD), all of these responsibilities have been consolidated in RAD. This includes exposure assessment for workers, consumers, environmental, and general population exposures, as well as environmental fate.
The idea of centralizing all aspects of risk assessment in one Division has appeal as this should produce more coherent assessments where all of the technical issues are addressed and decided by a single management official, in this case, Dr. Tala Henry. Exactly how the various Branches in RAD would function is not clear, although the Branch Chiefs identified in the organizational chart bring discrete backgrounds in hazard and risk assessment in some cases while others have backgrounds in exposure assessment.
The former EETD has been renamed the Chemistry, Economics, and Sustainable Strategies Division under Dr. David Widawsky. As such, it includes responsibilities for the Toxic Substances Control Act (TSCA) Inventory and chemical nomenclature, economics analysis, Design for the Environment program, and a new Prevention Strategies and Implementation Branch that appears to be responsible for PPD's prior responsibilities in implementing the Pollution Prevention Act (PPA).
Other Divisions were generally unaffected by the reorganization.
The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.
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