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PBT Challenge Grant

PBT Challenge Grant

Establishing PBT Priorities:


Guidance for Applicants to the Region 9 Pollution Prevention Incentives for States and PBT Challenge Grant programs

For more information, contact:

John Katz
EPA Region 9


EPA is still developing a list for targeting PBTs for pollution prevention. There are, however, a number of efforts that have identified various PBT chemicals as high priority for national and international action. Rather than publishing a definitive list of priority chemicals at this time, EPA suggests potential applicants evaluate these lists below and any other relevant information to select those chemicals that fit local circumstances, such as media-specific concerns, industrial activity, etc. Many of the substances listed below are no longer manufactured or sold in the U.S., and may have limited opportunities for pollution prevention.

1. U.S. Canada Binational Agreement:

The United States and Canada have entered into an agreement to reduce loading of PBTs into the Great Lakes. Rather than use a new screening and assessment process, the Virtual Elimination Binational Strategy seeks to build upon the most recent and relevant science-based selection processes used in either country. These processes considered a wide range of factors such as chemical and physical properties, potential to cause cancer, toxicity, risk to human health and wildlife, presence in the environment, as well as adverse impacts observed in the environment. Asymmetries in the approaches or information used by the two nations, or in definitions of bioaccumulation produced some differences in lists identified by each country. However, because the Strategy is a binational activity, the final list of chemicals was the result of agreement on the nominations from the two countries.

Level I Substances

Substances were selected on the basis of their previous nomination to lists relevant to the pollution of the Great Lakes Basin Ecosystem. These included:

  • “Bioaccumulative chemicals of concern” (BCCs) from the “Final Water Quality Guidance for the Great Lakes System,” USEPA, March 1995;
  • Substances identified by the “Canada-Ontario Agreement Respecting the Great Lakes Basin Ecosystem (COA),” 1994;
  • Substances identified as critical pollutants by the International Joint Commission (IJC), 1987;
  • Substances designated “Lakewide Critical Pollutants” in Lakewide Management Plans (LaMPs);


As a measure of further corroboration for their environmental impact, reference was made to the persistent organic pollutants (POPs) of concern identified in the United Nations Environment Programme Governing Council Decision 18/32 of May 1995, and incorporated into the Council of the Commission for Environmental Cooperation’s Sound Management of Chemicals Agreement between the U.S., Canada, and Mexico (Resolution #95-5), October 1995.


aldrin/dieldrin 1,2,3,4,5 mercury and compounds 1,2,3,4
benzo(a)pyrene 2,3,4 mirex 1,2,3,4,5
chlordane 1,2,4,5 octachlorostyrene 1,2,4
DDT (+DDD+DDE) 1,2,3,4,5 PCBs 1,2,3,4,5
hexachlorobenzene 1,2,3,4,5 PCDD (Dioxins) and PCDF (Furans)1,2,3,4,5
Alkyl-lead 2,3,4 toxaphene 1,2,3,4,5

Note: EPA’s PBT Initiative is currently focusing on these twelve chemicals. For more information, see the PBTI web site at

Level II Substances

Level II substances are those for which one country or the other has grounds to indicate its persistence in the environment, potential for bioaccumulation and toxicity. These grounds have not as yet been sufficiently considered by both nations such that they can agree to set joint challenge goals for these substances at this time. Until and unless these substances are placed on the Level I list, the governments encourage stakeholders to undertake pollution prevention activities to reduce levels in the environment of those substances nominated jointly by both countries, and to conform with the laws and policies of each country with respect to those substances nominated by only one country.

cadmium and cadmium compounds 2,4 hexachlorocyclohexane 1,2,4,6
1,4-dichlorobenzene 2 4,4′-methylenebis(2-chloroaniline )2
3,3′-dichlorobenzidine 2 pentachlorobenzene 1
dinitropyren e2 pentachlorophenol 2
endrin 5 tetrachlorobenzene (1,2,3,4- and 1,2,4,5-) 1
heptachlor (and heptachlor epoxide) 5 tributyl tin 2
hexachlorobutadiene and hexachloro -1,3-butadiene 1 PAHs as a group, including anthracene, benzo(a)anthracene, benzo(ghi)perylene, perylene, and phenanthrene 2


  1. U.S. BCC
  2. Canadian COA
  3. IJC Critical Pollutant
  4. LaMP Lakewide Critical Pollutant
  5. POPs from CEC Council Resolution #95-5
  6. In Canada, all agricultural pesticides were excluded from the COA Tier II list and are dealt with separately under COA and are not Canadian nominations to this list.

2.Waste Minimization National Plan

EPA’s Office of Solid Waste’s Waste Minimization National Plan (WMNP) sets ambitious goals for the reduction of the most PBT chemicals in hazardous waste through voluntary pollution prevention activities. EPA is currently developing a list of priority PBT chemicals in hazardous waste, and published a draft list of 51 chemicals in November 1998. Background on the WMNP and the list of chemicals are available at

Though that list is currently being revised in response to comments, applicants can refer to the draft list and evaluate if those chemicals present opportunities for reductions in their area.

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