No Proof EPA Pollution Prevention Program Works as Claimed, Inspector General Says

By Pat Rizzuto

Sept. 11 — The Environmental Protection Agency has no proof that a key pollution prevention program has cut U.S. use of hazardous materials as claimed, the agency's inspector general said in a report released Sept. 9.

The agency also can't claim the pollution prevention program is cost effective because the program doesn't measure cost-effectiveness, the inspector general said.

In response to the report, the EPA said it has removed cost-effectiveness claims from the website describing its Design for the Environment (DfE) Safer Product Labeling Program.

The agency's response detailed other actions it already has begun to or plans to take to address the concerns the inspector general's report found. The EPA's response is included in the inspector general's report, “EPA Can Help Consumers Identify Household and Other Products with Safer Chemicals by Strengthening Its ‘Design for the Environment' Program.”

DfE's labeling program already allows more than 2,500 carpet cleaning products, dish soaps, floor care products, laundry detergent softeners and other consumer and institutional products to receive the agency's permission to carry a specific logo.

The DfE logo means a qualified third party has verified that all the chemicals used to make the product are among the safest compounds available for the particular function they provide. In addition, the product must perform well and be packaged in an environmentally friendly manner, the inspector general's report said.

Various Aspects of Labeling Effort Examined

The report evaluated various aspects of DfE's Safer Product Labeling program, including:

• claims the EPA makes about the program's benefits,

• consumer understanding of the logo the DfE Safer Product Labeling program uses, and

• EPA's oversight of manufacturers' use of the logo.


The IG said it found that the agency asserts DfE products are cost-effective.

The DfE program, however, doesn't have controls in place to assure cost-effectiveness, it said.

Similarly, the agency uses results from its DfE program to support claims that it has significantly reduced the pounds of hazardous materials used in the U.S. and increased the use of safer products, the report said.

“However, DfE results data are not appropriate or valid to support either measure,” the IG said.

In addition to removing the cost-effectiveness claims, the agency will no longer report pounds of hazardous materials reduced through pollution prevention nor a percent increase in the use of safer products, the report said.

Changed Metrics Have Limitations

Instead, the DfE program will track the number of products that have earned the DfE label and the number of chemicals—currently about 650—that are named on its Safer Chemicals Ingredients List, the report said.

“While the new measure is important, it has key limitations,” the inspector general said. “Counts of products that are labeled safer and chemicals on the Safer Chemical Ingredients List do not provide evidence that consumers are actually purchasing and using these products.”

On other issues, the inspector general recommended the agency periodically review manufacturers' compliance with the voluntary DfE program. For example, manufacturers are supposed to include on their product or website a disclaimer stating the DfE logo doesn't imply the EPA endorses their product.

In its response, the EPA said it already has begun to audit manufacturers' compliance. Those audits should be completed by the first quarter of fiscal year 2015 and will then continue, the agency said.

Problems Seen With Label

The inspector general said it found the current DfE logo does not adequately communicate to the consumer that the product is a safer product.

The logo also may imply to consumers that the EPA is endorsing DfE-labeled products, but agency endorsement isn't allowed, the inspector general said.

The EPA is in the process of redesigning the DfE logo, the agency said in its response. On Sept. 8, the EPA released for public comment several possible new logos it might use.

As part of the redesign, the EPA said it is working with its general counsel ensure the new design does not imply an endorsement.

Similar Concerns Voiced by Manufacturers

Kathleen Stanton, director of technical and regulatory affairs for the American Cleaning Institute, told Bloomberg BNA the inspector general's report described concerns cleaning product manufacturers have voiced to the agency for many years.

The cleaning institute is pleased the EPA has said it will follow all recommendations the inspector general made.

“The report is very good,” Stanton said.

The institute, however, would like to see the inspector general examine other aspects of the DfE program, Stanton said.

For example, when DfE partnerships examine chemicals that may substitute for a compound of concern, they use a particular approach to conduct an alternatives assessment, she said.

California Environmental Protection Agency is emulating many aspects of DfE's alternative analyses as the state agency prepares to implement its Safer Consumer Products Regulation, Stanton said.

It could be useful to have an inspector general report examine DfE's approach, she said.

To contact the reporter on this story: Pat Rizzuto in Washington at

To contact the editor responsible for this story: Larry Pearl at

The IG report, “EPA Can Help Consumers Identify Household and Other Products with Safer Chemicals by Strengthening Its ‘Design for the Environment' Program,” is available at