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Responding to Reduction Claims

To: Toxics Activists
From: Working Group on Community Right-to-Know
Re: July 1st Toxics Release Inventory (TRI) Deadline
Date: 7/2/89

On July 1, 1989, manufacturers subject to Title III, Section 313 (Toxics Release Inventory) were required to submit to their state and the U.S. EPA information about their routine release of toxic chemicals to the environment in 1988. This is the second TRI reporting deadline.

Manufacturers subject to Section 313 include facilities:

The importance of the TRI data is hard to underestimate. Indeed its value has already been demonstrated:

The July 1st deadline provides an important opportunity to renew debate on the dangers of toxic emissions and what can be done to reduce the use and disposal of toxic chemicals. By taking the offensive, you can set the context for the debate about toxic emissions. Use the numbers to place the burden on industry to explain why these toxic emissions are harmless.

You may also be asked by the media to respond to the high numbers or industry claims of reduction. The following are suggestions on how to respond to the data or reduction claims.

The TRI data illustrates the extent of the toxics problem

In many cases, the TRI reveals the startling extent to which industries use our environment as a dumping ground. Whether its air, land, or water, we reject industry's practices that threaten public health and the environment.

In fact, these figures underestimate industry's releases of toxic chemicals to the environment because (1) the TRI covers only basic manufacturers; (2) not all covered industries complied with the reporting requirements; and (3) only facilities manufacturing, processing, or using over 50,000 pounds are covered. Thus, there are many facilities not subject to Title III, Section 313 that pose a serious threat to public health and the environment.

"We are releasing such a small concentration of chemical "X" to the environment that it is not harmful to public health".

Dilution is not the solution to pollution! Again, industry should not be allowed to use our environment as a dumping ground. At the end of a year, the company has released _____ pounds of toxic chemicals into air, land, or water. Also, do not get caught in industry risk arguments. Your focus is on preventable risks. Many of these releases can be reduced and you want a commitment from the industry detailing how they plan to accomplish these reductions.

"We have used a more accurate method of estimating releases this year and have found them to much less than previously thought".

Re-estimation is not reduction. While we applaud efforts to better define the problem, we are looking for a commitment to finding solutions. Also, the amount of releases may still be unacceptably high.

"This information is already out of date. We have instituted measures to reduce our emissions".

Compare 1987 TRI submission with 1988 submission. Have emissions been reduced? Has the method of estimation changed? Any claimed reduction may have been due to re- estimation rather than in-process changes.

How did the company achieve its emissions reductions? Were the reductions attributable to a downturn in production? Re-estimation of emissions? De-listing of a chemical? (Many companies may claim large emissions reductions this year because sodium sulphate was removed from the TRI Toxic Chemicals List. Just because they don't have to report these emissions, it doesn't mean they have stopped releasing sodium sulphate into air, land, and water.)

Exactly what process did the facility change to achieve these reductions? Has the company reduced its emissions rather than its actual use of the chemical? Demand measures reducing the use of toxic chemicals. Reduced use means reduced risk. Facilities only reducing emissions can still subject workers to unnecessary risk from handling the chemicals. Also, out-of-process recycling (a method of recovering chemicals for reuse) subjects the workers and the environment to unnecessary risk because of transportation hazards.

"Our community relations department has regular meetings residents to discuss community concerns."

Are they willing to explain, process by process, exactly how current reductions have been achieved? Are they willing to develop a use reduction plan with goals and a timeline of when they will be reached? Are they willing to let community representatives and independent experts tour the plant?

Source: RTK Net, Washington DC

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