Are TRI releases really down? The following memo, circulated earlier this year by the Working Group on Community Right-to-Know, may help shed some light on the subject.
To: Environmental Reporters and Editors
From: Paul Orum, Working Group Coordinator
Re: Tracking Toxic Chemical Pollution
Date: May 22, 1992
On May 27, the U.S. Environmental Protection Agency (EPA) will release national Toxics Release Inventory (TRI) data. Under the spotlight of public attention, many companies emphasize reductions in toxic chemical pollution.
But what do these changes mean? Are they the result of pollution prevention? Pollution control? "Phantom reductions"?
The Chemical Manufacturers Association recently asserted that its members reduced reported toxic releases 35% from 1987 to 1990. And EPA Administrator William Reilly has announced that toxic chemical releases and transfers dropped 11% from 1989 to 1990.
The following sample questions should help the press and the public find out what these changes really mean. (See reverse.)
Independent surveys find few "real" reductions. A Citizens Fund report, "Manufacturing Pollution," revealed that only 13 of the top 50 facilities reporting reductions between 1988 and 1989 could point to investment in pollution prevention or control as the cause. Other reports, notably "Phantom Reductions: Tracking Toxic Trends," by the National Wildlife Federation (August 1990) have had similar findings.
Better data are needed. Any responsible company should be able to pinpoint the cause of year-to-year changes in TRI data. Each TRI report (called a Form R) includes a public and technical contact. EPA has established a phone number to help reporters and citizens locate and access toxics release reports: 202-260-1531.
Pollution Prevention Questions
Which specific reductions resulted from:
- substitution of safer chemicals?
- reformulation of products?
- modified production processes?
- improved operations or maintenance?
Pollution Control Questions
Which specific reductions were caused by:
- addition of pollution control equipment (including physical, chemical and biological treatment)?
Common examples of pollution control include scrubbers, filtration units, baghouses, mechanical separators, precipitators, incinerators (including burning as fuel) or other means of capturing or treating waste after it has been created.
Phantom Reduction Questions
Which specific reductions resulted from:
- decreased production?
- recalculation using different estimating techniques?
- unreported off-site shipments to "recycling"?
- redesignation of main business activity?
- de-listing of TRI chemicals?
The U.S. General Accounting Office acknowledges that 95% of the nation's toxic releases may not be included in TRI. What percent of emissions does the company spokesperson believe are not covered by the facility's own TRI reports?
If the company recalculated emissions using new estimating techniques, why were new methods used? Did the company also recalculate last year's emissions using the new methods?
Has the company filed any of the nearly 50 petitions received by EPA that would take chemicals off the TRI list? What chemicals would the company like to see added to TRI?
What have EPA and state regulators done to verify emissions at facilities? What verification is planned?
Has the facility adopted toxics use reduction goals and a company- wide program to reduce toxic chemical use?
Background to the Toxics Release Inventory (TRI):
The Emergency Planning and Community Right-to-Know Act of 1986 initiated national reporting requirements for industrial toxic releases to air, land and water. The data are widely viewed as a valuable source of environmental information.
The Pollution Prevention Act of 1990 adds information on source reduction (a form of pollution prevention) and also on recycling to the current TRI program. This expanded reporting begins with reports due on July 1 of this year.
Proposed Right-to-Know More legislation received a favorable vote (13 to 4) from the Senate Environment and Public Works Committee on April 30. The proposal amends the Resource Conservation and Recovery Act, adding more chemicals, facilities and types of data to TRI.
The Working Group on Community Right-to-Know is an affiliation of local, state and national environmental organizations concerned with the public's right-to-know about toxic pollution.
Source: RTK Net, Washington, DC
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