ting discretion is guided by a sophisticated set of pollution prevention objectives, statutory authority may not be a necessary prerequisite to detailed government regulation.

CONCLUSION

Pollution prevention as regulation also appears here to stay, raising concerns about the unanticipated rapid evolution of an intrusive regulatory system. The entanglement of pollution prevention with regulation almost inevitably will limit the flexibility that industry is hoping to find in nonadversarial pollution prevention. Thus industry, government, and environmental groups must critically examine the inner workings of pollution prevention and be vigilant to deter it from becoming a rationale for national industrial policy and a more intrusive form of regulation.

REFERENCES

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Blomquist, Robert F. 1991. The EPA Science Advisory Board's report on "Reducing Risk": Some overarching observations regarding the public interest. Environmental Law 22:149.


Environmental Protection Agency. 1991a. Pollution Prevention 1991: Progress on Reducing Industrial Pollutants. Washington, D.C.: U.S. Environmental Protection Agency, Office of Pollution Prevention.

Environmental Protection Agency. 1991b. U.S. EPA Progress in Meeting Congressional Mandates of Pollution Prevention. Washington, D.C.: Environmental Protection Agency, Office of Pollution Prevention.

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