Draft Climate Change Adaptation Implementation Plan

The Office of Chemical Safety and Pollution Prevention (OCSPP)

June 14, 2013
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Disclaimer

To the extent this document mentions or discusses statutory or regulatory 

authority, it does so for informational purposes only. This document does not 

substitute for those statutes or regulations, and readers should consult the 

statutes or regulations to learn what they require. Neither this document, 

nor any part of it, is itself a rule or a regulation. Thus, it cannot change or 

impose legally binding requirements on EPA, States, the public, or the 

regulated community. Further, any expressed intention, suggestion or 

recommendation does not impose any legally binding requirements on EPA, 

States, tribes, the public, or the regulated community. Agency decision 

makers remain free to exercise their discretion in choosing to implement the 

actions described in this Plan. Such implementation is contingent upon 

availability of resources and is subject to change. 
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Preface

The U.S. Environmental Protection Agency (EPA) is committed to identifying 

and responding to the challenges that a changing climate poses to human 

health and the environment.

Scientific evidence demonstrates that the climate is changing at an 

increasingly rapid rate, outside the range to which society has adapted in the 

past. These changes can pose significant challenges to the EPA’s ability to 

fulfill its mission. The EPA must adapt to climate change if it is to continue 

fulfilling its statutory, regulatory and programmatic requirements. The 

Agency is therefore anticipating and planning for future changes in climate 

to ensure it continues to fulfill its mission of protecting human health and 

the environment even as the climate changes. 

In February 2013, the EPA released its draft Climate Change Adaptation Plan

to the public for review and comment. The plan relies on peer-reviewed 

scientific information and expert judgment to identify vulnerabilities to EPA’s 

mission and goals from climate change. The plan also presents 10 priority 

actions that EPA will take to ensure that its programs, policies, rules, and 

operations will remain effective under future climatic conditions. The priority 

placed on mainstreaming climate adaptation within EPA complements efforts 

to encourage and mainstream adaptation planning across the entire federal 

government.

Following completion of the draft Climate Change Adaptation Plan, each EPA 

National Environmental Program Office, all 10 Regional Offices, and several 

National Support Offices developed a Climate Adaptation Implementation 

Plan to provide more detail on how it will carry out the work called for in the 

agency-wide plan. Each Implementation Plan articulates how the office will 

integrate climate adaptation into its planning and work in a manner 

consistent and compatible with its goals and objectives.

Taken together, the Implementation Plans demonstrate how the EPA will 

attain the 10 agency-wide priorities presented in the Climate Change 

Adaptation Plan. A central element of all of EPA’s plans is to build and 

strengthen its adaptive capacity and work with its partners to build capacity 

in states, tribes, and local communities. EPA will empower its staff and 

partners by increasing their awareness of ways that climate change may 

affect their ability to implement effective programs, and by providing them 

with the necessary data, information, and tools to integrate climate 

adaptation into their work.
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Each Program and Regional Office’s Implementation Plan contains an initial 

assessment of the implications of climate change for the organization’s goals 

and objectives. These “program vulnerability assessments” are living 

documents that will be updated as needed to account for new knowledge, 

data, and scientific evidence about the impacts of climate change on EPA’s 

mission. The plan then identifies specific priority actions that the office will 

take to begin addressing its vulnerabilities and mainstreaming climate 

change adaptation into its activities. Criteria for the selection of priorities are 

discussed. An emphasis is placed on protecting the most vulnerable people 

and places, on supporting the development of adaptive capacity in the 

tribes, and on identifying clear steps for ongoing collaboration with tribal 

governments.

Because EPA’s Programs and Regions and partners will be learning by 

experience as they mainstream climate adaptation planning into their 

activities, it will be essential to evaluate their efforts in order to understand 

how well different approaches work and how they can be improved. Each 

Implementation Plan therefore includes a discussion of how the organization 

will regularly evaluate the effectiveness of its adaptation efforts and make 

adjustments where necessary.

The set of Implementation Plans are a sign of EPA’s leadership and 

commitment to help build the nation’s adaptive capacity that is so vital to 

the goal of protecting human health and the environment. Working with its 

partners, the Agency will help promote a healthy and prosperous nation that 

is resilient to a changing climate.

Bob Perciasepe

Deputy Administrator

September 2013
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Draft: Climate Change Adaptation Implementation Plan

The Office of Chemical Safety and Pollution Prevention (OCSPP)

June 4, 2013

Background

On October 5, 2009, the President signed Executive Order (EO) 13514 on 

Federal Leadership in Environmental, Energy and Economic Performance1

. 

The EO established the Interagency Climate Change Adaptation Task Force 

and tasked it with delivering a report within a year with recommendations on 

policies and practices that Federal agencies can adopt that are compatible 

with and reinforce a national climate change adaptation strategy. The Task 

Force, co-chaired by the Council on Environmental Quality (CEQ), the 

National Oceanic and Atmospheric Administration (NOAA), and the Office of 

Science and Technology Policy (OSTP) delivered the report to the President 

on October 5, 20102

. One of its recommendations calls for all Agencies to 

develop a climate change adaptation plan. On March 4, 2011, the CEQ 

issued guidance for Federal agencies to implement climate change 

adaptation planning in accordance with EO 13514. That guidance sets a 

target for each agency to develop a policy statement and an adaptation plan. 

On June 2, 2011, the EPA Administrator issued a policy statement on climate 

change adaptation3. The statement commits the Agency to develop an EPA 

Climate Change Adaptation Plan to integrate climate adaptation into the 

Agency’s programs, policies, rules, and operations. The statement also 

directs all EPA program and regional offices to develop plans for 

implementing the Agency-wide Climate Change Adaptation Plan. The Agency 

 1 EO 13514, October 5, 2009. 

http://www.whitehouse.gov/administration/eop/ceq/sustainability 2 White House Council on Environmental Quality, Progress Report on the Interagency 

Climate Change Adaptation Task Force: Recommended Actions in Support of a National 

Climate Change Adaptation Strategy (Washington, DC, October 5, 2010). 

http://www.whitehouse.gov/sites/default/files/microsites/ceq/Interagency-Climate-ChangeAdaptation-Progress-Report.pdf 3 U.S. Environmental Protection Agency, Policy Statement on Climate-Change Adaptation, 

June 2, 2011. http://epa.gov/climatechange/Downloads/impacts-adaptation/adaptationstatement.pdf.
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provided its draft plan it to OMB and CEQ during the summer of 2012. The 

draft plan was publicly released on February 7, 20134

.

Each program and regional office was asked to develop an implementation 

plan, contributing to the Agency’s adaptation plan that addresses certain key

elements in its implementation plans. The elements considered include: 

programmatic vulnerabilities, priority actions, role in the Agency’s strategic 

measures, legal/enforcement, training/outreach, partnerships with tribes, 

impacts on vulnerable populations/locations, and evaluation to inform the 

organization’s efforts to integrate climate adaptation into its activities. 

Overview of OCSPP’s Role in Implementing Agency Strategic Goals

Goal 4 of EPA’s Strategic Plan is “Ensuring the Safety of Chemicals and 

Preventing Pollution”. OCSPP has the primary responsibility in its day-to-day 

decisions to ensure the safety of chemicals. OCSPP also is responsible for 

managing the Agency’s pollution prevention programs that are designed to 

prevent pollution at the source, promote the use of greener substances, and 

conserve natural resources.

Chemicals used to make our products, build our homes, protect property and 

crops, and support our way of life can end up in the environment and some 

may accumulate in our bodies. A changing climate can affect exposures to a 

wide range of chemicals. EPA’s efforts to assess chemical safety, and to 

implement chemical management decisions and pollution prevention 

programs to minimize exposures could be impacted by changing 

environmental conditions related to extreme weather events (e.g., 

increasing run off can increase pollution in nearby streams) or changing 

chemical use patterns (e.g., changing pest pressure can affect the use of 

agricultural chemicals). 

The regulatory framework that OCSPP uses to ensure chemical safety differs 

for pesticides and other industrial chemicals in commerce. Pesticides are 

regulated under the Federal Fungicide, Insecticide and Rodenticide Act 

(FIFRA) and under the Federal Food, Drug, and Cosmetic Act (FFDCA), which 

 4 EPA’s Draft Climate Change Adaptation Plan, February 7, 2013. 

http://www.epa.gov/climatechange/pdfs/EPA-climate-change-adaptation-plan-final-forpublic-comment-2-7-13.pdfhttp://epa.gov
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are managed by the Office of Pesticide Programs (OPP) within OCSPP. Other 

industrial chemicals in commerce are regulated under the Toxic Substances 

Control Act (TSCA), which is managed by the Office of Pollution Prevention 

and Toxics (OPPT) within OCSPP. OPPT also administers the Pollution 

Prevention Act through a series of programs that identify and leverage 

opportunities to prevent pollution.

Vulnerability Assessment 

The effects on the environment resulting from climate change pose new 

challenges to EPA as it strives to fulfill its mission of protecting human health 

and the environment. Challenges resulting from a changing environment due 

to climate change that may inhibit the Agency’s ability to fulfill its mission 

are referred to as vulnerabilities. Vulnerabilities can be a physical change in 

the environment causing increased exposure to chemicals or that may relate

to programmatic processes or tools that may need to be adapted as a result 

of a changing environment. This section discusses potential vulnerabilities to 

the Agency’s mission of ensuring chemical safety and preventing pollution. 

Overall, it is not likely the vulnerabilities discussed below will impede 

OCSPP’s ability to carry out its core mission of ensuring chemical safety and 

preventing pollution because many of its programmatic processes can be 

readily adapted to address changing environmental conditions, including 

those resulting from climate change. 

Changes in chemical exposure can result from the effects on the 

environment caused by a changing climate. For example, a changing climate 

can alter pest pressure or the location where crops are grown, which in turn 

may affect the rate, timing and/or frequency of chemical use. Changing 

environmental conditions may result in the introduction of new disease 

vectors or invasive species that could increase the demand for evaluating 

and making decisions regarding the safety of new chemicals or new uses of 

existing products to address public health threats. 

To make decisions on the safety of chemicals, EPA relies on the best 

available science and assessment tools and when quality monitoring data are 

unavailable, it relies on models to estimate exposures to chemicals. The 

primary vulnerability OCSPP identified for its chemicals management 

programs is to ensure that the tools and methodologies it uses remain 

robust so that they reasonably reflect environmental changes, including 

those influenced by climate change. 
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OCSPP is examining the ways in which its models and tools may need 

updating to account for changing environmental conditions and the potential 

effects of climate change. OCSPP has begun to review the potential 

implications of climate change for its current approaches to evaluating 

pesticide/industrial chemicals exposures to the environment and people 

including children, agricultural workers, and other groups who may be 

disproportionally exposed or affected.

The role of OPP is to make pesticide licensing and re-licensing decisions and 

conduct additional program activities to ensure that pesticides are used in a 

manner that is protective of human health and the environment. OPPT 

assesses the potential safety of new and existing industrial chemicals in 

commerce on human health and the environment using the same or similar 

models and tools as used to evaluate pesticide exposures. The 

methodologies and tools used to assess pesticide risks have been peer 

reviewed and are the state of the art used throughout the world. To ensure 

that the underlying science is sound in light of climate change, OCSPP is

evaluating its assessment tools to ensure that they address changes in 

important environmental factors resulting from climate change.

To assist with the evaluation of potential programmatic vulnerabilities, OPP 

consulted with the FIFRA Scientific Advisory Panel (SAP)5 to seek advice on 

areas within pesticide assessment processes that may be vulnerable to 

changing climatic conditions. OPP asked the SAP to provide guidance on its 

model review and preliminary conclusions, and on sources of information 

that may help fill knowledge gaps. The SAP concluded that climate change 

would likely impact pest pressure, how and where pesticides are used, and 

the quantity of pesticides used. The SAP agreed with OPP’s preliminary 

conclusion that since EPA reviews pesticide registrations at least every 15 

years using assessment methodologies that are conservative and protective 

of human health and the environment, it is expected that the assessments, 

and decisions based on them, will remain protective. 

One area of vulnerability identified by the SAP was the use of increasingly 

dated weather datasets in some models that estimate pesticide exposure. 

The SAP noted that the historical weather datasets might not fully reflect 

 5 The SAP is a Federal Advisory Committee established under the law to 

provide advice on pesticide-related science issues. 
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recent changes in climate and current weather trends. OPPT has similar 

concerns, especially in the assessment of chemicals that have the potential 

for large releases to air and resulting exposures to the environment and 

people, including children. Some of EPA’s exposure models that contain 

climate-related variables may need updating as weather patterns, 

temperatures, stream flow rates, air currents, precipitation rates, and other 

climate variables continue to change. With input from the SAP, OCSPP has 

begun to update its assessment approaches with the inclusion of current 

weather data to ensure that its assessments reflect current environmental 

conditions that could include factors affected by climate change. In the 

course of keeping its modeling capabilities current, as other information and 

resources become available, OCSPP may need to consider incorporating 

different assumptions or default environmental variables for physicalchemical properties that may vary with a changing climate and 

environmental conditions (pH, temperature, or flow rates). 

Extreme weather events and impacts to energy production and use are

important considerations in OCSPP’s Pollution Prevention Program. Limited 

availability of water and other natural resources are changing the way 

manufacturers produce products, driving them to look for new ways to 

reduce and reuse water and materials. Increased demands on energy are 

pushing businesses to streamline production processes and minimize waste. 

The Pollution Prevention program did not identify additional vulnerabilities to 

its programmatic capabilities that could result from changing climatic 

conditions. The program’s focus on water and energy conservation supports

approaches and practices that businesses, communities, and state and local 

governments will need to employ in order to respond to climate change.

Recognizing the critical role pollution prevention can play is an important 

environmental consideration within the context of climate change 

adaptation. The Pollution Prevention program did not identify specific

vulnerabilities to its programmatic capabilities that could result from 

changing climatic conditions although they may present new challenges. 

There may be other changes in environmental conditions that could impact 

chemical safety for which the Agency may need to consider. Rising sea levels 

and more frequent extreme weather events increase the vulnerability to 

flooding and destruction of structures in low lying areas. Chemical storage 

facilities may be located in low lying areas and could be at risk of increasing 

potential for chemical releases into the environment as a result of major 

weather events. Many farms are along major rivers, and storage facilities 

and businesses supplying pesticides can be in close proximity to the field 
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where pesticides are used. Similarly, industrial chemicals could be stored in 

low lying areas near ports along the seaboard, rivers, and other waterways. 

The Agency is not certain of the significance of this vulnerability; however, 

further study to determine the location of chemical facilities that may be at 

risk may be warranted. 
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Summary of Program Vulnerabilities to Climate Change Impacts on Chemical Safety

Climate Change Impact Likelihood of 

Impact 

Focus of Associated EPA 

Program

Likelihood EPA 

Program will 

be Affected by 

Impact 

Example of Risks if Program were Impacted

Goal 4: Ensuring Safety of Chemicals & Preventing Pollution

• Increasing extreme 

temperatures

• Increasing heavy 

precipitation events

• Very likely

• Likely

• Protecting human health and 

ecosystems from chemical 

risks. 

 

• Reduces pollution at sources

• Low

• Low

• Assure that chemical exposure models continue to be protective 

in light of changes in the environment 

• Changing in planting timing or location may affect the volume and 

timing of agricultural chemical use which could impact the 

appropriate risk management decisions.

• Changing pest pressure in agriculture and public health may place 

additional demands on the new registration, special local need 

and emergency exemption processes. 

• Chemical storage facilities may be located in low lying areas that 

may be increasing at risk due to sea level increases or an increase 

in severe weather events.

• Disruptions in energy or water supplies may increase demand for 

pollution prevention resources.
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Priority Actions on Climate Change Adaptation

To determine which potential programmatic vulnerabilities may warrant 

closer attention, OCSPP considered a number of criteria. Factors considered 

included the ability to quickly mainstream climate change adaptation into 

core processes, the likelihood for affecting core program goals, the scale of 

the potential impact, the timing of the impact, and the severity of the 

impact. Vulnerabilities that can readily be incorporated into core processes 

generally are addressed in OCSPP current approaches. These actions involve 

little additional cost to the program. Some actions are currently underway, 

while others may be addressed without additional resources.

OCSPP is positioned to address the effects of climate change and changing 

environmental conditions on chemical safety and pollution prevention. The 

principal challenge to the program is to ensure that the tools and models it 

uses adequately reflect the changes in the environment that may affect 

human health and the environment.

This section discusses climate change adaptation-related activities and 

processes that OCSPP can readily mainstream into its programs so that it 

continues to meet its protection goals.

Public Health Pesticide Registration

• The spread or introduction of certain public health pests can be 

attributed, in part, to climate change. OPP has and will continue to 

work aggressively with companies and researchers to identify safe pest 

control products and strategies to minimize adverse effects on public 

health.

Tools and Models

• Volatilization – In the past, the FIFRA SAP raised concerns that OPP’s 

current risk assessment approach does not consider off-site movement 

due to volatilization of pesticides. OPP now includes the potential for 

volatilization in its screening level assessments and will keep climate 

change in mind as it considers how to incorporate volatilization into its 

more refined assessments. 

• Developing a spatial component to PRZM/EXAMS – The Pesticide Root 

Zone Model (PRZM) simulates chemical movement in unsaturated soil 

systems within and immediately below the plant root zone. PRZM is 
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often linked with the Exposure Analysis Modeling System (EXAMS), 

which simulates the processes that occur in a water body situated next 

to an agricultural field. The FIFRA SAP suggested that OPP consider the 

geographic changes in pesticide use that will likely occur as a result of 

climate change. OPP is currently developing a spatial component to 

PRZM/EXAMS that it expects to complete by 2014. This model 

development effort is expected to more fully account for regional 

differences in cropping, pesticide use, and environmental conditions. 

These changes will help ensure that pesticide environmental 

assessment methodology is resilient to changes in real-world 

conditions, including those caused by climate change. 

• In the normal course of updating models and tools, OCSPP will

consider new pathways and changes in chemical behavior resulting 

from a changing climate.

• OPPT also has developed a geospatial component for its web-based 

IGEMS (Internet Geographical Exposure Modeling System) model to 

advance its higher tier exposure modeling capability to assess 

exposure to chemicals, calculating environmental concentrations in air, 

soil, water, and ground water. As resources are available, OCSPP 

could consider updating modeling capabilities to address changing 

assumptions or default variables for other physical-chemical properties 

that may vary with changing environmental conditions (pH, 

temperature, or flow rates).

Pollution Prevention

• OPPT’s Economy, Energy, Environment (E3) framework helps 

manufacturers reduce energy usage and conserve natural resources. 

Helping businesses to employ energy conservation techniques and 

discover new ways to reduce and reuse water and materials better 

positions them to respond to resource challenges that may result from 

climate change.

Specific information and data that would support OCSPP’s mainstreaming 

efforts include:

• Acquiring current weather data to incorporate into risk assessment 

tools. This effort is underway.
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• Acquiring, as the budget allows, up-to-date chemical use information. 

• Acquiring information to improve our understanding of the location of 

existing facilities and the effect extreme weather events might have on 

facilities in low lying areas. Acquiring such information would be a part 

of an Agency-wide mapping effort lead by the Office of Research and 

Development.

Agency-wide Strategic Measures on Climate Change Adaptation

The Agency’s Strategic Plan 2011-2015 includes a strategic goal to 

mainstream climate change adaptation into its programs. One specific 

mechanism for achieving the mainstreaming goal is through the 

development of scientifically sound decision tools. The primary mechanism 

by which the OCSPP will contribute to this goal is by ensuring that the tools 

used to assess chemical risks continue to provide robust estimates of 

potential risks in light of changing environmental conditions that may result 

from climate change.

Legal and Enforcement Issues

OCSPP believes that any changes in the conditions for regulating, approving,

licensing or regulating chemicals can be accomplished in the current 

regulatory or enforcement structure. 

Training and Outreach

Existing training and outreach programs within OCSPP can be used to 

communicate with, and educate the public about, any changes in the 

permitted use of chemicals that may result from changing environmental 

conditions. Internally, OCSPP will, as appropriate, encourage staff to 

participate in training developed across the Agency regarding mainstreaming 

of climate change adaptation into its programmatic work. 

Partnerships with States and Tribes
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OCSPP currently has existing mechanisms and strong partnerships with 

states and tribes which can be utilized to seek input and communicate 

programmatic activities related to climate change adaptation.

Vulnerable Populations and Places

Currently, OCSPP’s assessment and decision making approaches take into 

consideration the identification of populations that may be disproportionately 

affected by chemical exposures. One area that may warrant further crossagency discussion and investigation is the impact of the potential exposures 

to communities near chemical storage facilities in the event of a significant 

weather event.

Evaluation and Cross-Office Pilot Projects

Currently, OCSPP’s key chemical assessment tools and science policies are 

peer reviewed by the FIFRA SAP for pesticides and by the Agency’s Science 

Advisory Board (SAB) for other industrial chemicals. OCSPP would use 

independent peer review of any significant changes to assessment tools or 

models.