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Page 1: Helping the Auto Repair Industry Manage Hazardous Wastes: An

IntroductionThe Local Hazardous Waste ManagementProgram (LHWMP) is a multi-agency effortmandated by the state of Washington withthe goal of keeping hazardous and toxic

materials out of the environment througheducation and behavioral changes in indus-tries that generate hazardous wastes(LHWMP in King County, 1997; WashingtonState Department of Ecology, 2000). City and

county governments are responsible forassisting conditionally exempt small-quanti-ty generators (CESQGs) under this StateDepartment of Ecology mandate. CESQGsare businesses that produce less than 220pounds of hazardous waste a month and donot accumulate more than 2,200 pounds atany given time. By definition, CESQGs arenot subject to the requirements of theWashington State Dangerous WasteRegulations (WAC 173-303-070) if they 1)designate their waste in accordance with reg-ulations, 2) manage their waste so that itdoes not pose a potential threat to humanhealth or the environment, and 3) eithertreat or dispose of their dangerous waste inan on-site facility, or ensure delivery to anoff-site facility. The auto repair industry waschosen for the project reported here becauseof the number of past hazardous waste com-plaints received, the availability of industryinformation, and a need for a large sample toevaluate industry-wide practices. This indus-try is one in a series of industries that havereceived similar services since 1992.

MethodA team of environmental health specialists(the “Audit Team”) from Public Health–Seattle & King County, a partner in theLHWMP of King County, used specific feder-al Standard Industrial Classification (SIC)

From January 1, 2000, to August 31, 2001, a team of envi-ronmental health specialists from Public Health–Seattle &

King County, a partner in King County’s Local Hazardous Waste Management Program,made educational visits to 981 automotive repair shops. The purpose was to give the autorepair industry technical assistance on hazardous waste management without usingenforcement action. Through site inspections and interviews, the environmental healthstaff gathered information on the types and amounts of conditionally exempt small-quan-tity generator (CESQG) hazardous wastes and how they were handled. Proper methods ofhazardous waste management, storage, and disposal were discussed with shop personnel.The environmental health staff measured the impact of these educational visits by notingchanges made between the initial and follow-up visits.

This report focuses on nine major waste streams identified in the auto repair industry.Of the 981 shops visited, 497 were already practicing proper hazardous waste managementand disposal. The remaining 484 shops exhibited 741 discrepancies from proper practice.Environmental health staff visited these shops again within six months of the initial visitto assess changes in their practices. The educational visits and technical assistance pro-duced a 76 percent correction of all the discrepancies noted.

Laurence L. McKenrick, M.S.A., R.S.Keiko Ii, M.S.W., R.E.H.S./R.S.

Bill Lawrence, M.S.P.H., R.S.Michael Kaufmann, R.S.Mark Marshall, R.H.S.P.

Abstract

FEATURES

November 2003 • Journal of Environmental Health 9

Helping the Auto Repair Industry ManageHazardous Wastes: An Education Project

in King County, Washington

Page 2: Helping the Auto Repair Industry Manage Hazardous Wastes: An

codes from a database of King County busi-nesses to create a list of potential businesses tobe visited. Businesses with the following SICcodes were included in the study: 5510-01(car sales with repair), 7539-04 (electricalrepair), 7538-00 (general auto repair), 7539-03 (carburetor repair), 5561-02 (RV sales withrepair), 7538-01 (auto machine shops), 7533-00 (exhaust systems), 7539-01 (alignmentand suspensions), 7539-06 (radiator shops),7537-00 (transmission repair), and 7539-02(brake repair) (Executive Office of thePresident, Office of Management and Budget,National Technical Information Service,1987). Under these SIC codes, 1,155 autorepair facilities were identified.

Training materials were compiled inpreparation for the field visits, including theLHWMP Hazardous Waste Directory (2000),the LHWMP IMEX Materials ListingsCatalog (n.d.), and the Washington StateDepartment of Ecology Guide for AutomotiveRepair Shops (1999). Industry-specific bestmanagement practices (BMPs) for properhandling of each waste were developed inaccordance with the U.S. EnvironmentalProtection Agency (U.S. EPA) definitionand model, which defines BMPs as methodsthat have been determined to be the mosteffective and practical means of preventingor reducing pollution (U.S. EPA, n.d.). TheAudit Team staff also developed an“Observation and Recommendation” form

to record waste streams, identify disposalmethods, and recommend BMPs.

Two major objectives of the study wereidentified: 1) to gather baseline informationon how hazardous wastes were generatedand handled by the industry and 2) to evalu-ate and record changes made between theinitial and return visits. The following areasof concern were discussed during visits: haz-ardous waste disposal, methodology anddocumentation, stormwater discharge, sec-ondary containment, spill prevention or con-tainment of materials, and labeling of wastecontainers. The behavioral-change target wasset at 75 percent.

The Audit Team sent letters to 1,155 busi-nesses explaining the project. One hundredand seventy-four businesses were removedfrom the list for the following reasons: out ofbusiness or no longer at location (139), not inKing County (three), not an auto repair busi-ness (24), residential address/no contact withoccupants (four), and refused entry (four).(A shop refusing entry to an auditor was stilloffered written educational materials, and thestaff person observed the interior and theexterior of the building for obvious signs ofenvironmental problems.) Subsequently, theAudit Team conducted visits to 981 con-firmed auto repair shops between January 1,2000, and August 31, 2001. Finally, the fielddata were tabulated and analyzed to evaluatethe auto repair industry.

Findings

Waste Stream AnalysisThe amount of each hazardous waste streamthat was observed on site was quantified andrecorded on a hazardous waste checklist. Thechecklist was used to ensure consistency andaccuracy in data gathering. The waste streaminformation was obtained verbally from theowners or managers, and from waste dispos-al receipts maintained at the businesses.These data were then transcribed to a dataentry form and entered into a computer data-base. The waste generation rates for KingCounty automotive repair shops are shownin Table 1.

Waste OilOil was the most voluminous waste stream.Overall, 903 auto repair facilities (92 per-cent) produced waste oil. The average facili-ty generated approximately 194 gallons permonth. The industry as a whole generatedapproximately 175,000 gallons of waste oilper month in King County, which translatesto over two million gallons annually (Table1). Ninety percent of the businesses used alicensed transporter to haul the waste oil offsite. Of the 981 shops visited, only 84 shops(8.5 percent) supplemented their buildingheat by burning waste oil on site (see photoon page 11). The Audit Team was concernedabout a possible increase in air pollution

10 Volume 66 • Number 4

TABLE

F

1Waste Generated by 981 Auto Repair Shops in King County,Washington

Waste Streams From Aqueous From PetroleumParts Washers Parts Washers

Waste Oil Shop Antifreeze Batteries Aqueous Halogenated Non-halogenated UnknownOil Filters Towels Solvent Solvent Solvent Solvent

Number 903 567 759 668 659 55 43 419 134of businesses

Gallons 194 — — 41 — 10 7 9 15per month

Total gallons 175,182 — — 27,388 — 550 301 3,771 2,010per month

Items per — 116 433 — 9 — — — —month

Total items — 65,772 328,647 — 5,931 — — — —per month

Yearly totals 2,102,184 789,246 3,943,764 328,656 71,172 6,600 3,612 47,252 24,120for gallonsor items

Page 3: Helping the Auto Repair Industry Manage Hazardous Wastes: An

from the burning of used oil. This concernwas mitigated, however, by informationreceived from the Puget Sound Clean AirAgency (PSCAA), which authorizes the prac-tice of burning used oil in 500,000-BTU oilheaters in King County. So the two mil-lion–plus gallons of used oil generated annu-ally in King County could be a significantresource for heating the businesses in whichit is generated.

Oil FiltersOil filters are not regulated as a hazardouswaste if they are properly punctured anddrained for 24 hours prior to disposal as solidwaste, or if they are recycled, a process where-by both oil and steel are recovered. A total of567 shops (58 percent) reported generatingused oil filters. These shops averaged 116 fil-ters per month, creating an annual number inKing County of more than 789,000.

An oil filter, even after being drained, con-tains approximately 250 milliliters (mL), ornearly one cup, of oil. Two hundred and fifty-five of the businesses adequately drainedtheir filters but then disposed of them intheir solid waste containers. An annual vol-ume of nearly 355,000 filters was disposed ofin this manner. If all oil filters were crushedprior to disposal, an additional 23,000 gal-lons of waste oil could be recovered annual-ly in King County.

A typical automotive oil filter containsapproximately 0.5 pounds of metal. Theweight of the oil filters generated in one yearin King County is estimated, then, to amountto about 394,600 pounds, or 197 tons, of

metal. The weight generated by the 255 busi-nesses not engaged in recycling would beabout 89 tons. While some of these filterswere disposed of in King County, many weresent to landfills in the state of Oregon. Ifsolid waste regulators required that used oilfilters be recycled, approximately 89 tons ofmetal would be removed from the solidwaste stream each year.

Used Shop TowelsMost businesses sent used shop towels(woven cloth) to permitted commercial laun-dry facilities. Six businesses reported laun-dering towels at home. Home laundering isnot recommended because it may exposefamily members to hazardous materials; also,it is desirable to keep heavy metals and fats,oil, and grease (FOG) out of septic and sani-tary sewerage systems (King CountyDepartment of Natural Resources–IndustrialWaste Section, 2000).

AntifreezeSix hundred and sixty-eight auto repairshops (68 percent) reported generating wasteantifreeze. This waste was generated at anaverage of 41 gallons a month per businessand was usually sent off site to a treatment,storage, and disposal facility. Four hundredeighty one businesses (72 percent) used thismethod of disposal, while 167 (25 percent)reported processing the coolant on site withcommercially available recycling equipment.Twenty businesses (3 percent) stated thatthey generated very small quantities of wasteantifreeze and had never disposed of thematerial. Among this group, three reportedthat they took their waste antifreeze to ahousehold hazardous waste collection site,

and two had at one time or another illegallydisposed of their antifreeze into the sanitarysewer system. After they were made aware ofthe illegal disposal, these businesses claimedto have ceased this activity.

BatteriesSix hundred and fifty-nine shops (67 per-cent) generated used lead-acid batteries,which contain recyclable materials. Manyrecyclers accept lead-acid batteries, and han-dling this waste stream was not considered tobe a problem. The biggest issues were safetyand secondary containment. Because batter-ies contain sulfuric acid, any spills could bea possible threat to personnel or to the envi-ronment. Businesses were advised to place allof their used batteries in secondary contain-ment holders (containers that were inert tosulfuric acid) and also to maintain a contain-er of sodium bicarbonate for neutralizing anyaccidental spills.

Parts WashersParts washers were divided into two cate-gories according to the liquid they used:aqueous and petroleum-based (see photosabove). Of the 981 shops visited, 651 (66 per-cent) reported using one of these two parts-washing systems (Table 1). Approximately596 of these (92 percent) washed auto partsin a petroleum-based solvent. The remaining55 shops used aqueous parts-washing sys-tems, commonly referred to as “spray cabi-nets” since they resembled industrial-sizedishwashers. Traditionally, parts washing inthis industry has been done with petroleum-based solvents. Recent innovation in partswashing, however, has resulted in the devel-opment of aqueous systems.

November 2003 • Journal of Environmental Health 11

Typical aqueous parts washer. Typical petroleum parts washer.

Typical installation of used-oil burner in auto repair shop.

Page 4: Helping the Auto Repair Industry Manage Hazardous Wastes: An

The majority of auto repair shops in KingCounty sent their petroleum waste solventto an off-site facility. Twelve businesses (2percent) were found to be improperly dis-posing of the solvent from their parts wash-ers. These businesses either burned thematerial in a waste oil burner within thefacility, evaporated the material by leaving itin an open container, or discharged the sol-vent to the sanitary sewer. Proper disposalmethods were discussed with these busi-nesses. Because the LHWMP is not a regula-tory program, continuing violators werereferred to agencies with enforcementauthority.

Although aqueous parts washers wereused less than petroleum-based solvents,they produce a more complex and problem-atic waste. Waste from aqueous parts wash-ers contains both oily wastewater and asludge waste that accumulates at the bottomof the machine. Of the 55 businesses thatused aqueous parts washers, 36 businesses(65 percent) reported sending this waste(wastewater and sludge) to a licensed treat-ment facility. Eight businesses (15 percent)recycled the wastes on site, and seven shops(13 percent) said that they never disposed ofthis wastestream. Four shops (7 percent)admitted that they sent the waste to the san-itary sewer, an unacceptable disposal option.Alternative disposal methods were discussedwith the managers.

As auditors documented the uses towhich aqueous parts washers were put,questions arose about the disposal of thewastewater and sludge from this equip-ment. Therefore, wastewater and wastesludge from eight randomly selected autorepair shops in King County were sampled(Christensen, 2002). The wastewater wasanalyzed for total metals, volatile organiccompounds (VOCs), and FOG. The sludgewas analyzed for copper, nickel, zinc, andother metals; halogenated organic com-pounds (HOCs); and pH, according toestablished parameters and procedures(Washington State Department of Ecology,1998).

Test results demonstrated that all waste-water samples exceeded the local sewer dis-charge limit of 100 parts per million for FOGand 50 percent of the samples exceeded theKing County industrial-wastewater danger-ous-waste limit for lead or cadmium. Onewater sample exceeded the local dischargelimit for arsenic, three exceeded the limit forcopper, and six exceeded the limit for zinc.None of the samples showed VOC levels nearthe regulatory limit.

The sludge fractions of the samples had apH range of 7.5 to 11.3 and were not con-sidered CESQG hazardous waste by this cri-terion. One sludge sample did, however,exceed the hazardous waste limit for cadmi-um. Another sample was classified as a

Washington State “Special DangerousWaste” for HOCs. Test results were sharedwith each of the eight businesses, whichthen modified, if necessary, their disposalpractices for wastewater and sludge fromspray cabinets.

The above information may be helpful forthe regulatory agencies and vendors that pro-vide technical guidance and assistance to thisindustry as aqueous parts washers becomemore common.

Impact AnalysisThe Audit Team evaluated the impact of itseducational visit to a particular shop by eval-uating the changes made between the initialaudit and the return visit (Table 2). Changesmade in the following areas of concern weredocumented: hazardous waste disposal,methodology and documentation, stormwa-ter discharge, secondary containment, spillprevention, and labeling. A total of 484 auto-motive repair facilities (49 percent) requiredmore than one visit. Some businessesrequired multiple visits before improvementswere made. Surprisingly, 497 businesses (51percent) required only the initial visitbecause they were already handling haz-ardous waste correctly by using BMPs. Thefact that 51 percent of the identified autorepair businesses were in compliance indi-cates a high level of environmental aware-ness by this industry.

12 Volume 66 • Number 4

TABLE

F

2Changes in Waste Management Practices Made by 484 Auto Repair Shops in King County,Washington

Regulated Activities BMPs for Hazardous Wastes

Hazardous Stormwater Secondary Documentation Spill LabelingWaste Discharge Containment Materials

Disposal

Number with discrepancies 66 27 299 83 98 168on initial inspection

Number that made correction 50 22 215 56 75 118on follow-up inspection

Percent that made corrections 76 81 72 67 77 70

75% impact objective met? Yes Yes No No Yes No

Regulated average 79%

BMP average 72%

Overall average 76%

Page 5: Helping the Auto Repair Industry Manage Hazardous Wastes: An

November 2003 • Journal of Environmental Health 13

Hazardous Waste DisposalOf the 484 auto repair facilities that requiredfollow-up visits, 66 (14 percent) wereimproperly managing their hazardouswastes. Typically, a shop was not characteriz-ing its sludge or filters prior to disposal insolid waste. Information was given to thebusiness managers about the need for testingand obtaining a waste clearance, whichwould allow them to legally dispose of thematerial. Subsequent visits found that 50shops (76 percent) had changed their behav-ior in a positive way.

Stormwater and Surface Discharge ofHazardous WastesTwenty-seven shops (6 percent) were foundto be discharging wash water, antifreeze,waste oil, or other materials to storm drainsor directly to the ground surfaces, whichjeopardized the water quality of nearbystreams or other bodies of water. On the fol-low-up visits, 22 businesses (81 percent)had made corrections to prevent any futurecontamination. Five businesses (19 per-cent) did not alter this method of wastemismanagement, even after subsequent vis-its by field staff. Field staff referred thesebusinesses to agencies with enforcementauthority for follow-up.

Secondary ContainmentProviding secondary containment for haz-ardous waste or hazardous material is a BMPand is not a requirement for CESQGs. TheAudit Team recommended this practice, how-ever, in order to prevent hazardous wastefrom accidentally entering the environment.Many of the businesses stored drums of haz-ardous waste or material within the shop

building (see photo at left). Most buildingswere considered secondary containment, pro-vided that the wastes stored in drums couldnot spill into a floor drain or outside the shop.Containers should not be stored near a door-way. Some businesses chose to store theirwaste oil or waste antifreeze outside the build-ing, usually adjacent to the exterior of thebuilding. BMPs included placement of thewaste containers on a bermed imperviouspad, such as concrete or asphalt. The contain-ers were to be kept under a shelter to preventrainwater from entering the drums and fillingthe bermed area. Rainwater could cause thewaste to overflow and spill into a nearbystormwater drain or onto the ground.

Nearly 300 businesses were initially foundto have deficient secondary containmentpractices (Table 2). Return visits found that215 shops (72 percent) had made significantimprovements in their secondary contain-ment practices. Eighty-four businesses didnot change their practice for the followingreasons: cost of making changes, a realiza-tion that the changes were just a recommen-dation and not a requirement, and possiblefuture relocation of the business.

Documentation of Hazardous Waste DisposalProper completion of the manifest, receipt, orbill of lading showing proper documentation ofwaste disposal was recommended to limit theliability of the individual businesses (LHWMPin King County, 1994). Of the 484 businessesrequiring follow-up visits, 83 businesses (17percent) did not have adequate documenta-tion. Fifty-six businesses (67 percent) madeimprovements in this area. Complete disposalrecords, including manifests and certificate ofdestruction, minimize a generator’s future lia-bility, although CESQGs are required only tomaintain receipts or bills of lading.

Availability of Spill MaterialsWhen hazardous waste spills occur, a busi-ness can incur high cleanup costs, possiblelong-term liability, worker safety issues, andother problems. A fact sheet of basic infor-mation on the proper storage of materials,especially chemicals, was provided to thebusinesses to prevent future spills fromoccurring (LHWMP in King County, 2000).

Ninety-eight auto repair facilities (20 per-cent) lacked adequate plans and materials inthe event of a hazardous material spill.Seventy-five businesses (77 percent) correct-ed this discrepancy by the time of subse-quent visits.

Labeling of Hazardous Waste ContainersInitial inspections showed that 168 shops(35 percent) were not properly labeling theirwaste drums. Washington State Departmentof Labor and Industries requires that con-tainers with hazardous materials or wastes belabeled or marked with the identity of thecontents (State of Washington, Departmentof Labor and Industries, 2000). Follow-upinspections found that 118 shops (70 per-cent) had corrected this discrepancy.

ConclusionA total of 1,155 businesses were identifiedin 1999 as auto repair facilities. From thelist, 174 businesses were excluded for thefollowing reasons: out of business, out ofKing County, not an auto repair business,residential address/no contact with occu-pants, or refused entry. The remaining 981were visited between January 1, 2000, andAugust 31, 2001. During the initial visitsconducted by the Audit Team, 497 busi-nesses (51 percent) were identified asusing proper waste management and dis-posal practices. The other 484 shops (49percent) needed further assistance and vis-its. The fact that 51 percent of the autorepair shops were already in complianceindicated a high level of environmentalawareness by this industry. Follow-up vis-its were conducted at the 484 shops thatexhibited the discrepancies identified inTable 2. The educational visits and techni-cal assistance produced a 76 percent cor-rection of the discrepancies noted, and inaddition, hazardous waste managementand disposal practices were markedlyimproved. Thus, this auto repair projectdemonstrated that direct outreach to thecommunity, wide distribution of necessaryeducational materials, and eliciting ofcooperation can positively change haz-ardous waste management practices. Theeffort also indicated the importance ofbusiness and government collaboration inpollution prevention.

Acknowledgements: The authors would liketo acknowledge the following personnel fortheir special assistance in the development ofthis report:• for assistance in research and staff training

in preparation for the auto repair industryaudit:— Cynthia Balogh, King County

Department of Natural Resources,Water & Land Resources Division;

Inadequate secondary containment of wasteantifreeze—potential for spills outside the building.

Page 6: Helping the Auto Repair Industry Manage Hazardous Wastes: An

— Scott Lamb, Washington StateDepartment of Ecology, NorthwestRegional Office; and

— Paul Shallow, R.S., L.H.W.M.P., compo-nent coordinator, Public Health–Seattle& King County;

• for review of and comments on the draftauto repair report:— Hilary Karasz-Dominguez, Education

Consultant II, Public Health–Seattle &King County;

— Kimquy Kieu, M.D., M.P.H., sectionmanager, Environmental HazardsSection, Public Health–Seattle & KingCounty;

— Trudy Rolla, R.S., L.H.W.M.P., evalua-tion coordinator, Public Health–Seattle& King County; and

— Wally Swofford, R.S., supervisor,L.H.W.M.P., Public Health–Seattle &King County.

The LHWMP Audit Team consisted ofSteve Burke, Olivia Chamberlain, PennyChencharick, David Christensen, TerryClements, Keiko Ii, Michael Kaufmann, BillLawrence, Mark Marshall, Tracee Mayfield,Larry McKenrick, William Perry, PaulShallow, John Sipkens, Jill Trohimovich, andLinda Van Hooser.

Corresponding Author: Laurence L.McKenrick, Local Hazardous WasteManagement Program in King County,Public Health–Seattle & King County, 999Third Ave., Suite 700, Seattle, WA 98104-4039. E-mail: [email protected].

14 Volume 66 • Number 4

REFERENCES

S

Christensen, D. (2002). Characterization of the Waste of AqueousParts Washer Cabinets (Brochure # SQG-AMOTIVE-212130).Seattle, WA: Local Hazardous Waste Management Program inKing County.

Executive Office of the President, Office of Management andBudget, National Technical Information Service (1987). StandardIndustrial Classification Manual (NTIS No. PB 87-100012).Springfield, VA: Author.

King County Department of Natural Resources–Industrial WasteSection (2000). Discharging Industrial Wastewater in King County.A clear water partnership. (Brochure #0020jc.p65). http://dnr.metrokc.gov/wlr/indwaste/index.htm (4 August 2003).

Local Hazardous Waste Management Program in King County(1997). Local Hazardous Waste Management Plan for King County,Final Plan. Seattle, WA: Author.

Local Hazardous Waste Management Program in King County (1996).Hazardous Waste Directory 2002 (Brochure #SQG-GEN-1) (Rev. Jan.2002). http://www.metrokc.gov/hazwaste/yb/ (30 June 2003).

Local Hazardous Waste Management Program in King County,Washington (n.d., modified weekly). IMEX materials listings cat-alog. http://www.metrokc.gov/hazwaste/imex/. (30 June, 2003).

Local Hazardous Waste Management Program in King County,Washington (1994). Manifest and Shipping papers (Brochure#SQG-GEN-4) (Rev. Apr. 1999). http://www.metrokc.gov/hazwaste/lhwmp/manifests.html (30 June 2003).

Local Hazardous Waste Management Program in King County,Washington (2000). Preventing Spills—How to store materials sospills don’t happen (Brochure #SQG-GEN-14). http://www.metrokc.gov/hazwaste/lhwmp/spills.pdf (30 June 2003).

State of Washington, Department of Labor and Industries WISHAService Division (2000). Understanding “Right to Know”: ChemicalHazard Communication Guidelines for Washington Employers(Brochure #F413-012-000). Olympia, WA: Author. http://www.lni.wa.gov/IPUB/413-012-000c.pdf and http://www.lni.wa.gov/IPUB/413-012-000nc.pdf (7 July 2003).

Washington State Department of Ecology, Hazardous Waste andToxics Reduction Program (1999). A Guide for Automotive RepairShops (Publication #92-BR-12, Rev. Feb. 1999). http://www.ecy.wa.gov/pubs/92br12.pdf (18 June 2003).

Washington State Department of Ecology (1998). Chemical testingmethods for designating dangerous waste (Publication No. 97-407).http://www.ecy.wa.gov/biblio/97407.html (18 June 2003).

Washington State Department of Ecology (2000). Dangerous wasteregulations, Chapter 173-303 WAC (Publication No. 92-91,Amended June 2000). http://www.ecy.wa.gov/biblio/wac173303.html (18 June, 2003).

U.S. Environmental Protection Agency (n.d.). Best ManagementPractices (Updated June 2003). http://www.epa.gov/ebtpages/pollbestmanagementpractices.html.

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Electronically reproduced, with permission, from theJournal of Environmental Health, November 2003, apublication of the National Environmental HealthAssociation (www.neha.org).