Approved December 1, 2000, by the WEF Executive Committee

The Water Environment Federation believes the development of environmental regulations and standards should consider cross-media transfer of pollutants and the full range of environmental effects and improvements resulting from the decision at hand.

During the past three decades, significant strides to control, reduce, and/or eliminate environmental contaminants have been made worldwide. Yet, legislative and regulatory schemes have largely focused on individual media (i.e. air, water, solid waste, etc.). This approach may have been appropriate during the initial enactment of these laws. In some cases, however, the individual-medium approach of the past clearly has resulted in the transfer of pollutants to other media, rather than actual removal of pollutants from the environment or reduction in toxicity. Stringent parameter limits in wastewater discharges, for example, have resulted in the generation of increased quantities of wastewater residuals, which sometimes contain the very pollutants originally intended to be controlled by the Clean Water Act. Likewise, remediation of groundwater contaminated with volatile and semi-volatile organics can lead to increased emissions of volatile organic compounds into the air depending on the treatment technology employed.

WEF believes that federal, state, and local environmental officials should adhere to the following guidelines when formulating, implementing, or evaluating new environmental laws, regulations, policies or other guidance documents for environmental professionals:

1. New legislative or regulatory initiatives involving control of a particular medium under which pollution is merely shifted to a less regulated "dumping ground" should be avoided.

2. Pollutant prevention, reduction, or removal at the source or point of generation is often the most cost-effective and desirable approach for controlling or reducing environmental degradation.

3. Exposure risk implications of pollutant control should be considered (i.e., in which medium the pollutant is most stable, least damaging, or most isolated from potentially affected individuals or ecosystems).

4. Standard setting (or changing) procedures should incorporate examination of cross-media effects, and where some cross-media transfer is inevitable even with maximum economically achievable pollution control, risk assessment should be used to select the regulatory option that results in the least overall impact.

5. Realignment of, or improved coordination between, regulatory personnel involved in standards development and technology evaluation should be undertaken within state and federal agencies to assure sound cross-media decision-making. At a minimum, regulatory review procedures should provide for assessing cross-media implications.

The Water Environment Federation believes that more careful consideration of the cross-media impacts of environmental decisions will lead to improved water quality and a healthier environment overall.