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Comments of Carolyn Hartmann, US PIRG, on TRI-Phase 3:
Use Expansion, September 28, 1994

My name is Carolyn Hartmann. I am a staff attorney with the U.S. Public Interest Research Group. U.S. PIRG is the national lobbying office for state PIRGs. State PIRGs are nonpartisan, nonprofit environmental and consumer advocacy organizations.

Thank you for allowing me to present my views today on the "Chemical Use Inventory." The establishment of a Chemical Use Inventory, if properly constructed, is one of the most important pollution prevention initiatives that the U.S. Environmental Protection Agency could take in the short term.

EPA's five year strategic plan, "The New Generation of Environmental Protection," includes some very important "guiding principles," including pollution prevention, environmental accountability, strong science and data, and environmental justice. A publicly accessible database on toxic chemical use is key to each of these principles.

To date, the vast majority of activities -- be they legislative, regulatory or voluntary -- that this agency has undertaken, have focused on controlling pollution after it has already been created rather than working to prevent pollution in the first place. As the EPA Office of Pollution Prevention and Toxic's Phase 3 issues paper states, "what gets measured, gets done." Unfortunately, nearly all of the data collected by the EPA continues to focus at "end-of-pipe" pollution problems.

Until the EPA, states and industries begin to shift their focus to the source of the toxic pollution problems the Agency will not achieve a meaningful shift in environmental programs toward pollution prevention, increased environmental accountability, strong science and data, or environmental justice. EPA's five year strategic plan will accomplish little and end up on a shelf somewhere with past Administrations' strategic plans. Promising Agency initiatives like the "Common Sense Initiative," "Source Reduction Review Project," and multimedia permiting projects will fall short of their goals.

Toxics use data provides the basis for establishing an information system that cuts across environmental media and begins to link together the separate environmental statutes. Public reporting on the use of toxics, at a production process level, will help begin to shift the focus of EPA, State and industry activities to the source of toxic pollution problems. By definition, pollution prevention takes place at the production process level. Until we start measuring at that level, can not expect to achieve our pollution prevention goals.

In addition to focusing a chemical use inventory on the production process level, it is critical that this inventory be accessible to the public. The Toxics Release Inventory provides the best available framework for making this data available to the public. Public access to use data combined with the other data in TRI will provide workers, consumers and communities with a more complete picture of the toxic chemicals that are entering their everyday lives. It also helps citizens play a more active role in deciding which toxics risks they are willing to live with and which are simply unacceptable.

The Chemical Manufacturer's Association summed it up well when they coined the phrase, "Track Us. Don't Trust Us." Until citizens have access to the information necessary to track the flow of toxic chemicals from production to use to disposal, this "trust" will not exist.

One final word about another initiative currently underway at the EPA; the TSCA Inventory Udpate Rule (IUR). I am extremely concerned that the IUR track will provide very little useful information to the Agency and almost no useful information to the public. Some of the information that could be useful, like the "conditions of use" data will most likely not be available to the public. Despite these shortcomings, IUR will place additional burdens on industry, and on the Agency's limited resources and will prevent the Agency from focusing on the much more important goal of creating a publicly accessible Chemical Use Inventory.

We urge the EPA to make the establishment of a publicly accessible, Chemical Use Inventory one of the Agency's top priorities.

Source: RTK Net, Washington DC

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