Sierra Club Conservation Policies
Toxic Air Pollutants
- The U.S. Environmental Protection Agency (EPA) must begin immediately to identify those
toxic substances that are hazardous air pollutants, list them as such, and regulate them.
Legislation should be enacted to set a strict timetable for the EPA to accomplish this. At
a minimum, 30-40 substances shall be reviewed, and where appropriate, regulated, over the
next four years.
- The EPA shall review, for potential health impacts, toxic air pollutants that may be
reasonably anticipated to result in an increase in mortality, or an increase in serious
irreversible or incapacitating reversible illness. The EPA should use the best evaluative
techniques and data available, and consider toxicity, relative exposure factors,
cumulative and synergistic effects, and formation of hazardous air pollutants in the
environment from precursors.
- Once a toxic substance is identified and listed as a hazardous air pollutant, the EPA
shall set standards that protect people with an ample margin of safety, as required under
the Clean Air Act.
- Such toxic air pollutants as carcinogens for which threshold levels have not been
determined, or for which there are no health-effect thresholds, must be given special
attention. If the EPA administrator determines that a goal of zero emissions cannot be
achieved and a technology-based standard is used, the standard should require the use of
the best controls available, at least as stringent as those recently in use by similar
sources. The EPA should require stringent levels of control, including the elimination of
use of the toxic substance and /or the substitution of a less toxic substance. The
required levels of control shall be re-evaluated periodically in the light of new
- The EPA shall have primary responsibility for controlling hazardous air pollutants.
Working closely with the EPA, states shall conduct surveys to identify toxic air
pollutants with local impacts. Information from these surveys shall be provided to the EPA
to guide decisions on which additional substances should be reviewed and, where
appropriate, regulated. State and local governments may adopt standards more stringent
than those of the EPA and timetables that accelerate compliance with EPA deadlines.
- The EPA shall establish a committee of health professionals, scientists, and other
qualified experts, including, if appropriate, members of the Scientific Advisory Board and
the Clean Air Scientific Advisory Committee, to review available information and make or
review recommendations concerning levels of control, priorities, and research needs for an
effective hazardous air pollutants control program.
- Congress and the administration should provide the EPA with adequate resources for
health research and development of control technology. A substantial increase in funding
to adequately address hazardous air pollutants is needed over the next two years.
- Public input and appeal shall be an integral element of the hazardous air pollutant
Adopted by the Board of Directors, December 1-2, 1984