One principal shortcoming of traditional environmental regulation has been its general ineffectiveness to advance more environmentally benign manufacturing, production, and product use practices in the economy. This results partly from failing to meaningfully evaluate and prevent environmentally harmful or wasteful practices in commerce and instead merely attempting to control resulting pollution through technological fixes at the "end of the pipe."¹

A new toxics use reduction law in Oregon may be a bell-weather for an approach to environmental regulation that addresses pollution at its origin as well as at the discharge pipe.² The Oregon Toxics Use Reduction and Hazardous Waste Reduction Act³ (the Act) establishes a statewide policy of encouraging reduction in use of toxic substances⁴ and generation of hazardous waste whenever technically and economically practicable. Significantly, the Act gives priority to reducing toxics use rather than simply reducing hazardous waste generation.⁵