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Toxic Chemicals
Because the 33/50 Program was voluntary, the EPA sent invitations to companies
to solicit their participation. In the spring and summer of 1991, the EPA sent invitations to 5,000 companies to participate in the program, focusing on facilities reporting to TRI on any of the targeted chemicals from 1988 to 1994. Another 2,500 more
invitations were sent over the next three years. The EPA concentrated the majority
of their outreach on the top 600 companies with the largest releases and transfers.
A total of 1,294 facilities (16 percent of those invited) accepted the invitation to
participate in the program.
Participants in the program examined production processes and identified costeffective P2 practices. The companies were then to write a simple letter to the EPA
stating their reduction goals and plans. The EPA asked that companies focus their
reduction and release strategies on their waste management hierarchy, evaluating
source reduction first and then looking for opportunities to recycle, treat, or dispose
of wastes. Any steps taken to reduce the targeted chemicals were not enforceable
unless the activities were otherwise required by law or regulation. The success
of the 33/50 Program was measured according to whether reductions had been
achieved nationwide, with reductions looked at as an aggregate of total releases of
all 17 targeted chemicals.
BASIS FOR PROGRAM
The public release of TRI data in 1988 was the basis for the 33/50 Program. Soon
after the first release of TRI data to the public in 1989, public citizen groups placed
full-page ads in the New York Times highlighting the top 10 corporate air, water,
and land polluters. Some of these companies approached the EPA and pledged their
commitment to improve their environmental performance, which in effect started
the 33/50 Program (Arora and Cason 1996).
The EPA then conducted high-level meetings with chief executives of major corporations, industry trade associations, and environmental groups, looking for ways to use
the TRI data to reduce chemical releases. These meetings led to the 33/50 Program.
The purpose of the 33/50 Program was to demonstrate whether voluntary regulation by the industries could supplement the traditional command-and-control
approach of the EPA by bringing about targeted reductions more quickly than
regulations alone would. This program is an example of voluntary environmental
regulation that was national in scope, involved multimedia (integrating all media
to reduce releases to air, water, and land), and was prevention oriented. The program also sought to foster a P2 ethic, encouraging companies to consider and
apply P2 approaches to reduce their environmental releases rather than traditional
end-of-the-pipe methods for treating and disposing of chemicals in waste.
PROGRAM REQUIREMENTS
There were no specific mandatory guidelines developed by the EPA for the 33/50
Program. The companies could set their own reduction commitments that were truly
voluntary and not enforceable by law. A company’s participation in the program did
not preclude it from its responsibilities for complying with all other laws.