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Testimony of Guy O. Williams Delivered to U.S. EPA,
Office of Pollution Prevention & Toxics on Behalf
of National Wildlife Federation's Great Lakes Natural
Resource Center, September 28, 1994

The National Wildlife Federation is the nation's largest, not-for-profit, environmental education and advocacy organization with over 4 million members and supporters. NWF's mission is to educate, inspire and assist individuals and organizations of diverse cultures to conserve wildlife and other natural resources and to protect the earth's environment in order to achieve a peaceful, equitable and sustainable future. In addition to its headquarters in Washington, D.C., NWF operates regional "resource centers" in Ann Arbor, Michigan; Anchorage, Alaska; Portland, Oregon; Missoula, Montana; Boulder, Colorado; Bismarck, North Dakota; Atlanta, Georgia; Montpelier, Vermont and Austin, Texas. The staff of each resource center work with NWF state affiliates and other citizen groups on regional environmental issues.

NWF's Great Lakes Natural Resource Center (GLNRC), opened in 1982, is devoted to the protection and enhancement of Great Lakes water quality and protection of the Lake Superior ecosystem. The GLNRC provides legal, scientific and policy assistance to its Great Lakes affiliates and other Great Lakes environmental groups. The GLNRC is one of the few Great Lakes organizations that combines legal and scientific expertise with citizen education and advocacy efforts. We have established a reputation as one of the most effective Great Lakes organizations through the skills of our staff and as a result of projects such as our Lake Michigan Sport Fish Consumption Advisory Project and recommendations for reforming Great Lakes programs, such as A Prescription For Healthy Great Lakes, Protecting a Superior Lake, Saving All the Pieces and Hormone Copycats.

I'd like to open my remarks by affirming our conviction that our primary goal is to reduce and in some cases eliminate production, use of, and exposure to toxic substances. Toxic substances are poisoning us and companies have a responsibility to let us know what dangers we may be facing.

Much of the recent work of our office has been framed within the context of working for implementation of the Great Lakes Water Quality Agreement. Of particular concern to us are the class of toxic substances which are persistent and bioaccumulate. Mercury, dioxin and PCB's are examples of such toxins. We are encouraged by your strategy of empowering pollution prevention initiatives by providing information and support to the public. TRI as it now stands could be improved to provide even further encouragement of pollution prevention and to allow thorough assessment of pollution prevention gains at any given facility.

We see materials accounting data as a significant enhancement to the current TRI. This also is important as a national level program. The information that can become available through materials accounting would be a crucial tool for those people who currently suffer the disproportionate impacts of our modern chemical society. There of course would be a need make this information as accessible as possible.

One example of an existing program is the Michigan Critical Materials Registry. This registry includes over 100 chemicals and requires use of any amount over 1 lb of a listed substance be reported. Lower thresholds for reporting such as in this case are an important element to be included in any chemical use inventory. The definition of use here includes chemicals, "manufactured, stored, discharged in wastewater, disposed of as other waste materials (residuals), or otherwise present either alone or as components of other host materials which are present as a result of your business activity." Information from this registry was a critical part of the research conducted by U.S. EPA's Great Lakes National Program Office as part of their work to virtually eliminate persistent toxic substances from the Great Lakes Basin. Information on mercury and PCB's obtained from the Michigan Critical Materials Registry were a significant part of the background material for last weeks' meeting of EPA's Virtual Elimination Pilot Project. The registry showed a total of 273 facilities reported mercury useage in 1991. The same data base showed that a total of 360 facilities reported using over 12 million lbs. of PCB's in 1991. This is an excellent example of how national, state and eco-system based projects can benefit from accurate and complete information.

As a participant in earlier meetings with EPA on this issue, you should have on record that we are supportive of including all six basic calendar year throughput measures into any materials accounting requirements. We also, favor tracking substitution and the inclusion of occupational demographics data.

In closing, I'd simply like to echo the sentiments of the many today who have urged you to make implementation of a thorough chemical use inventory which includes facility level reporting, among the highest priority issues of your office.

Source: RTK Net, Washington DC

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