|Development of Standards for Evaluating the Importance of Contaminants in the Environment:
A Win-Win Partnership Between the U.S. Environmental Protection Agency and ASTM Committee E47
by Timothy J. Canfield and Christopher G. Ingersoll
As with many efforts to develop standards, there is often a group on the regulatory side and a group on the user side of the equation. Although the groups on either side may differ in perspective depending on the issue at hand, these differences can serve as an impetus for the development of standards through a consensus-based process. In the case of Committee E47 on Biological Effects and Environmental Fate, the primary player on the regulatory side has been the U.S. Environmental Protection Agency.
You might imagine this interaction would frequently be difficult or contentious. Although some of the discussions can get quite heated at times, in fact the opposite is true the working relationship is good with numerous positive outcomes. The EPA was instrumental in the formation of Committee E47 on Biological Effects and Environmental Fate and many of its employees have been heavily involved with the committee over the past 25 years in developing more than 100 ASTM standards dealing with methods for assessing the fate and effects of contaminants released into the environment.
E47s Founding in Context
To fully understand the relationship between EPA and Committee E47 we need to go back to the 1970s and early 1980s. In the time from World War II up to the early 1970s, when the EPA was established, toxicity tests had been used extensively to determine the effects of potentially toxic substances released into the environment. These tests were used to evaluate industrial effluents, pesticides, and heavy metals. (1) The early toxicity tests were performed with freshwater organisms, especially fish, but the advent of conducting toxicity tests with estuarine and marine animals and algae, which had markedly different life cycle requirements from freshwater fish, prompted the need for the development of standard testing methods. Although ASTM Committee D19 on Water had developed a standard dealing with aquatic toxicology methodology prior to this time, few people knew about this method and it was not widely used. Thus this trend to conduct tests in a standard way was a relatively new concept in the 1970s.
In 1971, the Committee on Methods for Toxicity Tests with Aquatic Organisms was formed to develop a set of test methods for aquatic organisms. This committee comprised representatives from EPA, the U.S. Fish and Wildlife Service, industry and academia; their effort culminated in an EPA publication on acute toxicity tests. (2) Shortly after this publication came out, the Committee on Methods was dissolved because it was felt that a move toward the development of standards through the consensus-based process would be the best approach. ASTM was a logical choice for carrying on the work outlined by the original Committee on Methods, and thus many members of this group joined ASTM Committees D19 or E35 on Pesticides to continue efforts for standards development.
During the 1970s, the United States faced an energy crisis defined by dwindling domestic supplies of oil, increasing reliance on foreign sources of oil and increased energy use across the country. (Sound familiar?) President Jimmy Carter signed the United States Synthetic Fuels Act of 1980 (Public Law 96 - 294; 94 Stat. 633 et seq) with the focus on developing synthetic fuels in order to reduce the countrys reliance on foreign sources of oil. These synthetic fuels, or synfuels as they were known, would be produced from tar sands or oil shale, as well as from gasification or liquification of coal by a process using high temperatures or pressure. (3)
But along with the development of these technologies came new potential environmental problems with the effluents resulting from these production processes. Additionally, methods were also needed to address the long-term scientific and regulatory needs of the newly enacted Toxic Substances Control Act. In the 1970s, most of the work that related to the field of aquatic toxicology in ASTM fell under the jurisdiction of Committees D19 and E35. There was a feeling of frustration, primarily in the aquatic toxicology community, with the limitations of the scopes of both Committee D19 and Committee E35, which made the development of standards for aquatic toxicology difficult. It was felt that development of standards needed to be addressed under the auspices of a single committee. On Oct. 9, 1980, an organizational meeting was held at ASTM Headquarters and Committee E47 was formed.
Those present at this organizational meeting represented a wide array of interest groups including various government organizations and industry. These professionals were well aware of the challenges ahead as they ventured forth into the area of consensus-based standards development.
One of those founding members of E47 is Charles Stephan who is still with the EPA. He felt that although EPA had the power to be judge and jury, this was not in the best interests of EPA in the long run. He knew there were many scientists outside of the EPA who had good ideas and had generated data that would be critical to the development of robust standards. The best way for EPA to produce better products, such as guidance on methods for conducting toxicity tests, was for members of EPA to work effectively with many other organizations. This concept, although fairly common today, was a great departure from the command-and-control mentality prevalent in EPA at the time, and one that was far ahead of its time.
Employees of the EPA played a major role in the formation and operation of E47. Those individuals committed themselves to this effort because they felt standards developed by ASTM would be a benefit to the field of environmental toxicology and to the efforts and challenges that faced EPA. Those outside EPA benefit by having a place in the development process that gives them a true sense of ownership and the opportunity to influence standards and methods requirements. The benefit to EPA is that the agency can cite an ASTM standard as a method to follow or the agency can use the ASTM standard as a basis for developing a stand alone EPA method. Either way, the EPA effort to develop methods is reduced and the legal challenges to those methods are minimized since the development process is a consensus-based effort open to all interested parties.
One success story that highlights the tremendous benefit of these interactions between the EPA and ASTM is of the development and publication of ASTM Standard E 729, Guide for Conducting Acute Toxicity Tests with Fishes, Macroinvertebrates and Amphibians. The development of this standard was principally coordinated by Stephan of the EPA. This was a landmark standard for Committee E47 and demonstrated how well the EPA and ASTM could and should work together. This standard, first published in 1980, can rightfully be described as the fundamental document for aquatic toxicity testing worldwide. As Stephan says Its where everyone starts, and everything in aquatic toxicology builds from that document. (4) The document took some time to develop, but those that worked on it were dedicated to producing the best document they could that would help guide those conducting acute toxicity tests. Although this standard has stood the test of time and has been revised as needed, the real success of this standard and the quality of the work that went into producing it was recognized by the EPA, as it was cited in its publication entitled Guidelines for deriving numerical water quality criteria for protection of aquatic organisms and their uses. (5) These 1985 guidelines, as they are known, have been used ever since as EPAs methodology for deriving national aquatic life criteria.
The Last Decade
Over the past decade, there has been an increased level of collaborative interaction and willingness on the part of EPA to engage in the ASTM process. This greater level of interaction has corresponded to greater interaction between EPA and other government and standards organizations including the Organization for Economic Cooperation and Development (OECD). This level of interaction has played out especially well in the development of methods for assessing the toxicity and bioavailability of contaminants accumulated in sediments.
In 1987, Committee E47 established Subcommittee E47.03 to develop standards for assessing the toxicity and bioavailability of contaminants associated with sediments, sludge, drilling fluids, and similar materials. Committee E47 provided a forum for scientists and managers to meet twice yearly to debate and discuss approaches for conducting sediment assessments and development of standards through the use of ASTM subcommittee meetings, workshops, and symposia. Important to the process was that representatives from government organizations such as the EPA, U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, and Environment Canada were able to leave their organizational hats at the door along with members from industry and academia to discuss various approaches to developing standards for assessing the toxicity of contaminants in sediment.
In 1990, the first ASTM standard guides were developed by Subcommittee E47.03. These were:
E 1391, Guide for Collection, Storage, Characterization, and Manipulation of Sediments for Toxicological Testing;
E 1383, Guide for Conducting Sediment Toxicity Tests with Freshwater Invertebrates; and
E 1706, Test Method for Measuring the Toxicity of Sediment-Associated Contaminants with Freshwater Invertebrates.
ASTM guides that provided a series of options for testing were initially developed because the state of the science was not well enough established to develop more specific ASTM test methods. Additional ASTM guides developed in the early 1990s included:
E 1688, Guide for Determination of the Bioaccumulation of Sediment-Associated Contaminants by Benthic Invertebrates;
E 1563, Guide for Conducting Static Acute Toxicity Tests with Echinoid Embryos;
E 724, Guide for Conducting Static Acute Toxicity Tests Starting with Embryos of Four Species of Saltwater Bivalve Molluscs;
E 1611, Guide for Conducting Sediment Toxicity Tests with Marine and Estuarine Polychaetous Annelids; and
E 1676, Guide for Conducting Laboratory Soil Toxicity or Bioaccumulation Tests with the Lumbricid Earthworm Eisenia Fetida.
These ASTM standards are routinely used in local, regional, national, and international programs to assess the bioavailability and toxicity of contaminants associated with sediment or soil. Data generated from studies using these ASTM standards have been used to make decisions regarding the need for source control, remediation, and restoration of contaminated sediments or soils.
During the 1990s, both the EPA and Environment Canada developed their own methods for collection and handling of sediments and for conducting whole-sediment toxicity tests with freshwater, estuarine, and marine invertebrates. Importantly, these methods were harmonized with existing ASTM standards. Over the past five years, information described in these EPA and Environment Canada documents have been used as the basis to revise the existing ASTM standards (e.g., methods for conducting chronic toxicity tests, methods for collection and handling of sediments). During this time period, Subcommittee E47.03 has also begun to develop more specific test methods rather than guides based on more detailed methods published in the scientific literature (i.e., E 1706 and E 1367, Guide for Conducting 10-Day Static Sediment Toxicity Tests with Marine and Estuarine Amphipods). The OECD has also used ASTM, EPA, and Environment Canada documents as a basis to develop their own methods for conducting freshwater sediment toxicity and bioaccumulation tests.
Ideally, multiple organizations would come to ASTM to develop a single set of standards through the ASTM consensus process. However, institutional requirements within these organizations have made this challenging (e.g., EPA has often expressed a difficulty citing ASTM standards by reference). Over the next five years, Committee E47 plans to continue to work with EPA and other organizations to try and develop single sets of standards through ASTM that will address each of their organizational needs (e.g., to be in better compliance with OMB Circular A-119 on federal participation and use of voluntary consensus standards). This will result in reducing inconsistencies among documents that develop over time and will more efficiently use the limited time individuals have to develop standards.
Committee E47 has provided a forum for scientists and managers to meet twice yearly to debate and discuss approaches for conducting tests to determine the importance of contaminants released into our environment and the development of standards through the use of ASTM subcommittee meetings, workshops, and symposia. Important to the process was that representatives from government organizations including the EPA were able to leave their organizational hats at the door along with members from industry and academia to discuss various approaches to developing standards for assessing the fate and effects of contaminants in the environment. The future for continued interactions between ASTM and EPA looks bright.
The common purpose we share in developing standards to produce the highest quality data remains the glue that holds this interaction together. Although we could both go our separate ways, the realization that we work better together than apart is clearer now than ever before. Interactions on standards may always develop into heated discussions, but when the day is done, the nations interests are best served through consensus rather than litigation. We can hold our heads high knowing the resulting standards are better for the fact that we sat at the table together and worked out our differences as part of the ASTM consensus-based process. //
(1) Parrish, P.R. 1985. Acute Toxicity Tests. In Fundamentals of Aquatic Toxicology G.M Rand and S.R. Petrocelli, eds. Hemisphere Publishing Corporation, Washington. pp 31-57.
(2) Committee on Methods for Acute Toxicity Tests with Aquatic
Organisms: Methods for Acute Toxicity Tests with Fish, Macroinvertebrates, and Amphibians. EPA-660/3-75-009, 1975.
(3) Griest W. H., Guerin M.R., and Coffin D.L., 1981 Health Effects Investigation of Oil Shale Development, Ann Arbor Science Publishers, Ann Arbor, MI.
(4) Juliani C. Landmark Standard for Aquatic Toxicology Subcommittee. ASTM Standardization News. April 1994.
(5) U.S. Environmental Protection Agency. Guidelines for deriving
numerical water quality criteria for protection of aquatic organisms and their uses. EPA-822/R-85-100, 1985.
Acknowledgments: We would like to thank the following individuals for providing information and insight about the history of ASTM Committee E47: Charles Stephan, EPA, Duluth, Minn.; William H. Kirchhoff, founding chair of E47; Larry Turner, EPA, Arlington, Va.; Larry Kapustka, ecological planning and toxicology, inc.; and Greg Linder, USGS/ BRD/CERC, Brooks Ore.
Copyright 2003, ASTM