October 18, 1995
The Unison Institute
1742 Connecticut Avenue, NW
Washington, DC 20009
Voice: (202) 797-7200
FAX: (202) 234-8584
Email: [email protected]
Internet Site: rtk.net
Let us begin today by agreeing that the Toxic Release Inventory (TRI) is a "work in progress." None of us, including industry, EPA, environmental advocates, and the public at large, is content with TRI as it stands. However, this admission is not just a condemnation of the TRI. To the contrary, we all have hailed the TRI as one of the singular successes of the EPA. Our admission is merely a recognition that The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and the Pollution Prevention Act of 1990, both set forth goals and a process for EPA to further determine how the TRI should be improved as we collectively become more aware of what we need to do to better use the extraordinary tools now at our disposal. Now after nearly ten years of experience, we have learned a great deal.
It has been well documented that the TRI has contributed to significant reductions in toxic chemical releases at relatively low cost. Environmental advocates point to a better understanding of the location and magnitude of pollution problems. Industry has proclaimed the benefits of avoiding "command-and-control" regulation in favor of enlightened self- interest. Government has recognized that the public can intelligently and responsibly act in its own behalf without the direct expenditure of government funds. Let's hope everyone in this meeting room will agree that we have a "win-win-win" situation.
Nonetheless, many of us recognize that we need more than a "fine- tuning" of the TRI. To a great extent, wholesale changes are necessary. We applaud EPA for some of these changes that are in process, including both the chemical and facility expansion efforts (although we must also urge EPA to accelerate and further expand these efforts which have taken much too long.) However, let's concentrate today on another wholesale change that needs to be made - holding the TRI to the same standard we set in the corporate world - double-entry bookkeeping. We must be sure that the TRI "books are balanced" so we all can make the numbers add up in the same way. If the books are set up the right way, we won't need chemical accountants to tell us if we're making a profit or a loss. That is the underlying promise of chemical use information for pollution prevention.
We also have to recognize that industry does have certain legitimate concerns. Although we can't point to any egregious examples, we must pay attention to industry's complaint that it is too easy for the unsophisticated casual user to improperly add up submission sub-totals and not understand what is actually going on inside the factory gate. This is especially true as we try to deal with complex pollution prevention issues under the PPA. Similarly, it seems that many of us forget that about 50% of the reported volume of chemicals passes from one plant to another, frequently to sites who in turn do not need to submit TRI reports. There are other gigantic omissions that we ignore - toxics in products, worker exposure, international trade, and more.
However, these complaints do not negate the other features of TRI that we want to maintain and enhance. EPA has established a reasonable approach to dealing with confidential business information. EPA's reporting and data processing mechanism is on a firm footing, properly balancing the issues of local responsibility and access with centralized quality control. Finally, EPA has undertaken steps to extend the discipline of the TRI by trying to make it the "backbone" of efforts to reduce reporting burden and increase our ability to integrate the TRI approach into other media programs. Thus, our challenge is to find the right balance of reporting and monitoring whereby we can continue to urge industry to find economical, if not profitable, ways to reduce the dangers of toxic chemical use.
Today, we should encourage EPA to further embrace that challenge. At least we should compliment EPA's Issue Paper #2, which evenly deals with the process to establish this balance (although with the amount of time that has transpired we would hope that they would be further along; this dialog has been going on for some time and it's long past due for EPA to more clearly lay out what they intend to do.) Their authority is not really at issue. Under the mandate provided by the umbrella of legislation including EPCRA, TSCA, PPA, and other acts, EPA can call for much more information, in a more timely manner, than is being suggested here. After all, what is the true risk to fast-moving international firms from data that is more than two years old by the time it is released? How much extra work can there be to compile data that any responsible facility manager needs to know anyway in order to optimize plant operations and safety procedures?
In that light, let me reinforce our support for several principles that EPA set forth in their Issue Paper. First, with materials accounting information, we will improve our ability to analyze what the real threats are from toxic chemical use. We will better understand the true sources, scope, and destination of toxics and the role of individual facilities. Concomitantly, industry must recognize that a comprehensive facility-based approach to materials accounting is preferable to micro- management and detailed process-level risk assessment. Second, we will better understand the health, safety, and related occupational risks of our workers, both blue collar and white collar, inside our industrial facilities. Moreover, we will be helping them prepare for and deal with many currently unknown risks. Third, we will better understand the eventual destination of toxic chemicals that are distributed through products, especially at a time when health concerns are widespread. In turn, this will give us the best means for determining in what ways the TRI should continue to evolve. Fourth, we will be better able to compare facilities in a fair and even-handed basis, taking into account their unique features and differences. We won't have to rely upon incomplete methods that don't take into account the largest flows of chemicals into and out of our industrial plants.. Fifth, we will improve the accuracy of the numbers themselves, by providing for cross-checks that eliminate errors or oversight. Sixth, we can encourage our corporate leadership to spread its advanced techniques for chemical management and guarantee the level of professionalism we have come to expect from U.S. industry.
Personally, I'm optimistic. The risks associated with materials accounting are limited and easily corrected if we move in the wrong direction. Many representatives of industry have voiced their support for this way of tracking toxic chemical flows if we can maintain a level-playing field and provide them with enough safeguards to protect confidential business information. Let's commend EPA for their goals and their work so far, and urge them to move ahead on comprehensive materials accounting.
Source: RTK Net, Washington DC
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