Agency
Off.ce c< Prevention. Pest odes an:: Toxic Substances EPA .700'R-92-005
Washington. DC 20400 Apri! 1992
c/EPA
Proceedings
INTERNATIONAL CONFERENCE ON
REPORTING RELEASES OF Toxic CHEMICALS
November 13-15, 1991 • Vienna, Austria
Sponsored by the
Office of Prevention, Pesticides, and Toxic Substances
U.S. Environmental Protection Agency
/;; conjunction with the
Organization for Economic Cooperation and Development
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Proceedings
INTERNATIONAL CONFERENCE ON
REPORTING RELEASES OF Toxic CHEMICALS
November 13-15,1991 • Vienna, Austria
Sponsored by the
Office of Prevention, Pesticides, and Toxic Substances
U.S. Environmental Protection Agency
in conjunction with the
Organization for Economic Cooperation and Development
-------
Prepared by JT&A, inc. and Abt Associates, Inc. under contract 68-DO-0020 for the
Office of Prevention, Pesticides, and Toxic Substances, U.S. Environmental Protection
Agency. Publication does not signify that the contents necessarily reflect the views and
policies of the Environmental Protection Agency or of any other organization
represented in this document. Mention of trade names and commercial products does
not constitute endoresement of their use.
TO OBTAIN COPIES, CONTACT:
National Technical Information Service
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(800) 553-6847
(703) 487-4650
Printed on recycled paper.
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Contents
Introduction v
Toxics Release Inventory:
Environmental Information for Government, Industry, and the Community
An Overview of the United States' Toxics Release Reporting Program 3
Mary Ellen Weber
An Introduction to the Data 9
Linda A. Travers
Other Perspectives on Toxics Release Reporting
Canada's Green Plan and the National Pollutant Release Inventory 19
Gordon Pope
A Public Interest Group Perspective 27
Gerald V. Poje
An Industry Perspective on Reporting Releases of Toxic Chemicals 33
Elizabeth A. Fisher
Breakout Sessions'
Implementation and Program Issues of the U.S. Toxics Release Inventory (TRI) 41
Mary Ellen Weber, Sam Sasnett, Warren R. Muir, Earl R. Beaver, and Robert Costa
Information Management 45
Linda Travers, Steven D. Newburg-Rinn, Gerald V. Poje, and Robert Wevodau
Computer Tools for TRI Analysis 49
Loren Hall, Robert Palmer, and Gary Hamilton
Data Use and Analysis
Setting Environmental Priorities with the Toxics Release Inventory 55
Mary Ellen Weber
Air Quality and the TRI 57
Denise Devoe
The Toxics Release Inventory — American Journalism's New Arrow in the Quiver 65
Bud Ward
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Initiatives Generated by the TRI
Industry Initiatives at the Community Level 71
Earl R. Beaver
Local Initiatives in TRI Reporting: The SCORECARD Model 75
Paul L Hill
Public Initiatives at the National Level 79
Warren Muir
Public Interest Group Initiatives at the Local Level 83
Ted Smith
Closing Plenary
Implications of Toxics Release Reporting for Other Countries 91
Richard P. Wells, Shinichi Aral, Andrew Lees, Hans-Peter Baars, Christopher Ian Pickard,
Jack Holland, and Maria Kazmukova
List of Attendees 97
iv
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Introduction
In 1991, the U.S. Environmental Protection
Agency and the Organization for Economic
Cooperation and Development jointly spon-
sored the International Conference on Reporting
Releases of Toxic Chemicals to demonstrate the
uses and applications of the Toxics Release Inven-
tory, the United States' national database of toxic
chemical releases to the environment. Held in
Vienna, Austria, this conference brought together
104 delegates from western and central European
nations, Australia, Canada, Japan, and the United
States.
As a result of a major chemical accident at
Bhopal, India, in 1984, and the commitment of
public interest groups to assure that the public
would be provided with information about
chemicals in their communities, the U.S. Congress
passed the Emergency Planning and Community
Right-to-Know Act (EPCRA) in November 1986.
EPCRA has two main purposes: prepare com-
munities for chemical emergencies that result
from accidental releases and provide the public
with information on chemicals stored on-site and
on chemical releases to the environment.
The conference explored one facet of EPCRA,
the requirement that manufacturing facilities pro-
vide the government with annual reports on their
releases of toxic chemicals to the environment.
This section of EPCRA, known as the Toxics
Release Inventory (TRI), also requires that data be
made available to the public. The pollutants
covered under EPCRA have the potential of caus-
ing acute or chronic health effects and/or en-
vironmental hazards. Data collected for TRI
include the types of toxic chemical releases; es-
timates of the amounts released into the air,
water, and ground; estimates of the amounts of
waste transported to other sites; and reports on
how chemical wastes are treated on-site. Since
1987, the United States has required manufactur-
ing facilities that meet certain criteria to submit
annual reports on the specified toxic chemicals
that their facilities routinely or accidentally
release into the environment.
The Toxics Release Inventory allows the
government, industry, and the public to estimate
the annual emissions of certain chemicals in a
specific geographic region. This information, in
turn, gives organizations the ability to substan-
tiate the need for further investigations and/or
regulatory action, examine environmental risks at
the national and local level, and influence the
sources of industrial pollution.
The International Conference on Reporting
Releases of Toxic Chemicals was designed to:
• demonstrate the usefulness of a TRI
system,
• provide participants with the basic
information necessary to build their own
emissions database programs, and
• encourage the sharing of toxics release
information between governments.
Structure of the Conference
The conference was geared toward environmental
policymakers, technical staff (such as toxi-
cologists and chemical engineers), risk assess-
ment managers, information systems staff, and
health professionals. A wide range of topics was
covered, with a concentration on the analytical
potential of the TRI, computer modelling
capabilities, and implementation and program-
matic uses.
The first plenary session described basic in-
formation about TRI and presented the Canadian,
public interest, and industry perspective. The
second plenary session presented information on
the use and analysis of data as well as industry,
news media, and public interest group initiatives
generated by the TRI.
To facilitate smaller group discussions, three
concurrent breakout sessions were held: Im-
plementation and Program Issues of the U.S.
Toxics Release Inventory; Information Manage-
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Reporting Releases of Toxic Chemicals
ment; and Computer Tools for TRI Analysis. All
of the breakout sessions were repeated three
times during the conference, allowing the par-
ticipants to attend each session. The breakout ses-
sions included presentations and a question and
answer period. In addition, there were ongoing
demonstrations of how TRI data are made avail-
able through various sources, including computer
programs used in analyzing toxics release data.
The conference concluded with a session on
the implications of toxics release reporting for
other countries. Representatives from four
countries — The Netherlands, the United
Kingdom, Australia, and Czechoslovakia — and
from two multinational organizations — the Or-
ganization for Economic Cooperation and
Development and Friends of the Earth — served
as panelists to provide a global perspective on
TRI-like concepts.
Organization of this Document
The papers contained in this proceedings are
given in the order in which they were presented
at the conference. These papers are transcripts of
the presentations. The issues, comments, and
common themes raised during each of the three
breakout sessions have been summarized by the
moderator or a panel member.
vi
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Toxics Release Inventory:
Environmental Information for
Government, Industry, and
The Community
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An Overview of the United States'
Toxics Release Reporting Program
Mary Ellen Weber
Economics and Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
ABSTRACT
The Toxics Release Inventory (TRI) is the first database ever created in the United States that
combines information regarding releases of pollutants to air, water, land, and underground in-
jection on a chemical-by-chemical and facility-by-facility basis. This presentation will describe
the origins of the TRI, the concept of public access to environmental information in the United
States, and the reporting requirements in terms of which chemicals, companies, and types of in-
formation are collected. It will discuss the data that have been reported and the resources
needed by government, the public, and industry to design and implement such a program.
I am the director of the Economics and Tech-
nology Division in', the U.S. Environmental
Protection Agency's Office of Pollution
Prevention and Toxics. My division is responsible
for writing the regulations that design and imple-
ment the Toxics Release Inventory, which we
often call the TRI.
The second speaker this morning is Linda
Travers, who is my partner in Toxics Release In-
ventory activities. As the director of the Informa-
tion Management Division, she makes sure that
the data are collected, properly entered into a
computerized database, managed, and then made
available to interested parties.
On behalf of the U.S. Environmental Protec-
tion Agency, I would like to thank the Organiza-
tion for Economic Cooperation and Development
(OECD) for encouraging us to have this con-
ference. I would also like to thank in advance the
many speakers who will share their knowledge of
and history with the Toxics Release Inventory in
the United States.
We are privileged to have more than 20
countries represented here today. I recognize that
English may be a problem for some of you and
am sorry we cannot provide translators. We want
to make this an informal exchange of information
and ideas, so do not hesitate to interrupt speakers
if you do not understand what they are saying.
The United States, as many countries, is
facing stiff challenges to its environmental policy.
The protection of the environment is no longer a
passing fad; it has become a major public policy
priority. EPA's administrator, William Reilly,
noted recently that the environment is moving
from the margins of public policy to the center. It
is now relevant in public policy areas where it
never was before, such as trade, international
economic policy, and foreign aid, and also in criti-
cal relations with many other important
countries, including Canada, Central Europe,
Brazil, and India, most of whom are represented
here today.
The environment is newly relevant even to is-
sues of war and peace, as witnessed by our con-
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Reporting Releases of Toxic Chemicals
cerns over the Kuwait oil spills and, of course, the
oil well fires.
Over a hundred years ago, a great conser-
vationist, Gifford Pinchot, stated that a nation
deprived of liberty may win it; a nation that is
divided may unite. But a nation whose natural
resources are destroyed must inevitably pay the
price: the penalties of poverty, degradation, and
decay.
There is a vital link between a prosperous
economy and healthy environment. Countries
have been ravaged by pollution. The air in some
of the larger cities is easier to see than it is to
breathe. And workers whose labor has con-
tributed to strengthening their countries'
economies are falling prey to a host of prevent-
able health problems caused or made worse by
tremendous pollution. Even vast agricultural
areas have become contaminated wastelands.
Protecting the environment and public health
is expensive but not doing so costs much more.
We estimate that the United States is spending
about 1.7 percent of its gross national product to
protect and clean up our environment — about
$115 billion. Many countries are doing more: Ger-
many and Canada, for example. The Netherlands
has made a policy choice to spend up to 4 percent
of its gross national product to protect the en-
vironment. We are delighted to have these
countries represented here today.
We are learning that it is more economical to
prevent pollution than to try to clean it up. Pollu-
tion prevention will be one of the major themes in
all of the presentations at this conference.
The idea of preventing rather than curing en-
vironmental problems has revolutionized en-
vironmental policy in the United States. It has
altered the way our government approaches the
environment, changed the way business views its
own interests and responsibilities toward the en-
vironment, and stimulated environmental aware-
ness and action by workers, students, and
consumers. International cooperation is more im-
portant now than ever because each of our
countries has limited resources and many
demanding public needs.
One of the ways to make productive use of
our environmental resources is to extend coopera-
tive relationships in other areas of public policy,
such as security, trade, or foreign aid, to the area
of environmental policy. Many of us are already
actively involved in OECD endeavors to har-
monize chemical testing and classification
protocols. And one of the goals of this conference
is to encourage the availability of toxics release in-
formation across national borders because pollu-
tion knows no boundaries.
Besides TRI, a number of other established
environmental database systems have demon-
strated the benefits of cooperation: the Global En-
vironmental Modelling System, Global Resource
Information Database, International Registry of
Potentially Toxic Chemicals, and the International
Referral System. The Earthwatch Program,
another ambitious international surveillance sys-
tem, monitors current conditions and changes in
the environment and serves as a global early
warning system.
Sharing this information between govern-
ments has been very useful. An increased under-
standing of the environment and the impact of
our daily activities helps us find new options for
protecting our world. The Toxics Release Inven-
tory program in the United States has proven that
sharing environmental information with the
public can improve environmental decisionmak-
ing.
Our purpose in this conference is not to sug-
gest that, to be useful, an emissions database
must be exactly like the TRI either in content or in
size. We do, however, believe that some common
elements would be important in designing any
toxic release emission database for your coun-
tries.
We will show you what we have learned
about the need for flexibility and expandability of
the kinds of data and the numbers of reports a
system can manage. We will discuss the
desirability of common chemical definitions and
classifications to establish consistent reporting
within a country across its economic sectors and
also across boundaries. Some countries, as you
will hear, are starting out with systems that have
much broader coverage than the TRI. Others may
choose to start on a smaller scale and grow over
time. But in any event, we are interested in learn-
ing from you what we have in common and what
you perceive to be the special needs of your ap-
plications of the TRI.
Background on TRI
In 1986, the TRI was enacted as part of the Emer-
gency Planning and Community Right-to-Know
Act (EPCRA) by the United States Congress and
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M.£. WEBER
signed into law by President Ronald Reagan. It is
the first publicly available database of toxic
releases to all media simultaneously, including
air, water, land, and underground storage. Its pur-
pose is to provide citizens with more accurate in-
formation about their environment so they can
make' more educated decisions about how to
manage it.
TRI has been one of the most powerful en-
vironmental policy tools ever wielded by a
nation's people. Subsequent sessions will focus
on how government, industry, the press, and the
public have used TRI information to target
resources and influence policy. The TRI has al-
ready been discussed at many international meet-
ings, and other nations' interest in it continues to
grow, as witnessed by this conference. You will
hear about other countries' initiatives in more
detail and what different groups are doing to cre-
ate similar reporting systems.
In the late 1970s and early 1980s, the United
States' government and several states passed laws
that gave workers the right to know about haz-
ardous chemicals in the workplace. At about the
same time, public interest groups focused on
providing communities with information about
exposure to chemicals beyond a plant's perimeter.
In December 1984, a terrible tragedy occurred
at the Union Carbide plant in Bhopal, India. A
deadly cloud of methyl isocyanate gas killed over
2,000 people and injured tens of thousands more.
Shortly afterward, a chemical release occurred in
West Virginia, a state near Washington, D.C. As a
result of increasing demands from the American
public to know what hazardous chemicals might
be released in their neighborhoods, Congress
passed the Emergency Planning and Community
Right-to-Know Act.
The act has two major purposes. The first is to
prepare communities for chemical emergencies
that result from accidental (unexpected and unin-
tended) releases; for example, if a railcar over-
turns or a plant explodes. The second is to give
the public information on approximately 300
chemicals and 20 toxic compounds whose use or
production could result in both routine and ac-
cidental releases to the environment.
EPCRA has four basic parts. The first three re-
late to the emergency planning component of the
community's right to know, as follows:
1. The emergency planning section of the law
helps communities prepare for and
respond to emergencies involving hazard-
ous substances by establishing local and
state emergency planning groups or com-
mittees.
2. EPCRA also requires facilities to notify the
community and the state if they release
substances accidentally, even if local plan-
ning groups did not have to respond to the
release.
3. Facilities must report the amounts, loca-
tion, and potential effects of any of 900
hazardous chemicals they might have on
their premises. This information is given to
fire departments and state and local
governments so, if there is an accident,
response teams will know how to deal
with the chemicals.
The fourth part of EPCRA, section 313,
created the TRI. In general, the Toxics Release In-
ventory requires that manufacturing facilities
compile an annual report to the state in which
they reside and the federal government estimat-
ing the total amount of chemicals routinely or ac-
cidentally released to the environment. EPA is
required to input these data into a computer
database, and once computerized, the data must
be made available to the public through computer
telecommunications and other means.
The TRI does not cover all sections or seg-
ments of our economy nor does it cover all toxic
chemicals. You will hear more about the logic and
implications of what is and is not covered under
TRI in subsequent presentations and particularly
in the breakout sessions. The TRI covers only the
manufacturing sector of our economy, which in-
cludes 20 broad classes of industrial facilities. For
example, it includes papermaking as well as
chemical manufacturing, metal processing, and
petroleum refining.
EPCRA was designed to minimize the report-
ing burden on small business. Thresholds were
set for manufacture, process, use, and import of
listed chemicals that trigger the reporting require-
ment, and the number of employees. Facilities
that manufacture, import, or process 11,400
kilograms (25,000 pounds) or more per year, or
use approximately 4,550 kilograms (10,000
pounds) per year of the listed chemicals and have
more than 10 employees, must file reports with
both EPA and the states.
The original list of chemicals and compounds
subject to TRI reporting was compiled by Con-
gress from lists assembled by two states,
Maryland and New Jersey. These states had estab-
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Reporting Releases of Toxic Chemicals
lished somewhat similar reporting systems before
Congress passed the act that created the federal
TRI.
The chemicals must be known to cause or be
reasonably expected to cause significant acute
human health effects at concentrations that are
likely to exist not inside the plant but beyond the
facility's site boundaries, as a result of continuous
or frequently recurring releases. Alternatively, the
chemical must be known to cause or be likely to
cause chronic health effects such as cancer and
teratogenic effects, serious or irreversible repro-
ductive effects, neurological disorders, genetic
mutations, or other chronic health effects. Finally,
if the chemical is known or expected to cause sig-
nificant adverse effects on the environment, either
because of its toxicity or because of a combination
of toxicity and persistence in the environment or
toxicity and a tendency to bioaccumulate in the
environment, it would meet the listing criteria.
Anyone can petition EPA to add or subtract
chemicals from the list. So far, about 40 petitions
have been filed to add or delete chemicals. The
data are reported in a separate annual report for
each chemical that includes an estimate of the an-
nual releases and transfers. This report is due six
months after the end of the calendar year in
which the releases take place.
The TRI covers all the environmental media.
Reports must specify total annual releases or
transfers of the chemical to air, water, land, under-
ground storage, publicly owned treatment facil-
ities, and other off-site locations. The facilities
report one number for the release of each chemi-
cal to each destination. However, they do not
have to report their highest daily or peak release
nor their daily average, and reported amounts are
estimated, not measured or monitored. Facilities
are required to report even if they have zero
releases of the listed chemical provided they have
met the manufacture, process, use, or import
threshold and have more than 10 employees.
TRI in the Future
A dynamic system, TRI continues to evolve.
During the early years of the TRI program, all of
our resources were devoted to getting the pro-
gram established and working well. More recent-
ly, we have been expanding the program in
response to demands from public interest groups,
industry, Congress, and individual citizens to
cover additional chemicals and facilities beyond
those in the currently covered manufacturing sec-
tor of our economy and provide more specific in-
formation (such as on peak release reporting) and
other ways to measure the amount of releases that
go into the environment.
EPA is working hard to juggle competing
demands for its resources. One of the ways we are
doing this is by developing criteria for chemical
list expansion. We are looking at toxicity require-
ments, production volumes, and a variety of other
things. As you are aware, it is neither a quick nor
easy task to identify toxicity characteristics of the
thousands of chemicals currently used in com-
merce or trade. We need help in targeting efforts
and developing our review process for the
thousands of chemicals that will be available as
candidates for TRI expansion.
TRI covers only the manufacturing sector of
our economy — primarily industries that deal or
can be expected to deal with large quantities of
specific chemicals. Some of the sectors being con-
sidered for expansion now are mining and, pos-
sibly, public utilities, public sewage treatment
facilities, chemical warehouses, and commercial
painters. Other operations that may represent
substantial sources of toxic chemical releases are
also being studied.
Another activity in which we are progressing,
thanks to Congress, is incorporation of pollution
prevention information in TRI reporting require-
ments. The TRI has, up to now, contained es-
timates only of releases and transfers of reported
chemicals. In 1990, Congress passed the Pollution
Prevention Act, which expands data collected
under TRI. Starting with the 1991 reporting year,
facilities must now estimate the total amount of
chemicals entering all waste or released directly
to the environment before any recycling treat-
ment or disposal. They will also report estimates
of amounts of chemicals recycled on-site and sent
off-site for recycling. Other important require-
ments of the Pollution Prevention Act include
company reporting of efforts to identify pollution
prevention or source reduction activities and ac-
tions facilities take to implement them. Another
key feature is the requirement for forecasting:
companies must report what they intend to do in
the future to make things better, not just tell the
public what they did in the past.
Peak release reporting is not dead at EPA. It is
another area that we are studying carefully under
the general rubrick of looking at what sorts of in-
formation make the most sense and are the most
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M.E. WEBER
useful for policy decisions by the private as well
as the public sector.
And finally, we are engaged in expanding
outreach. The more TRI is used, the more useful it
becomes to EPA, industry, and U.S. citizens. EPA
is continuing to promote the use of TRI by
developing tools, booklets, and training programs
that describe TRI and discuss how it can be used.
Conclusion
In conclusion, I would like to emphasize that TRI
has opened up the decisionmaking process. EPA
cannot address all the environmental challenges
facing our nation. We do not have the resources to
do everything at once, and we need to set
priorities to target environmental protection ef-
forts on the basis of opportunities for reducing
the most serious risks. Many methods can be used
to approach the problem. I will close this presen-
tation by discussing one approach that TRI has
fostered.
TRI has opened up the decisionmaking
process by providing the same information to all
interested parties — government, industry, public
interest groups, and individual citizens — at the
same time. In a democracy, the support of in-
dividual citizens is important to the success of
any national endeavor. In our effort to reduce en-
vironmental risk, such understanding and sup-
port is essential because the causes of and solu-
tions to environmental problems are often linked
to individual and societal choices.
Using TRI, EPA has expanded the amount of
environmental information available to the
public. TRI alone does not provide all the answers
that people need to protect the environment, but
it helps them ask better questions. An engaged
public can often help provide information that
supports our technical decisions. An informed
public operates less from emotion and more from
reason. Negotiation rather than confrontation can
result from the opening up of records required
under TRI.
We have seen that by encouraging and trust-
ing the public to interpret and work with these
TRI data, citizens have become more trusting of
the actions of government and industry. Rather
than saying, as we used to, trust the government
to take care of you or the industries to make the
right decision, TRI, in effect, says trust but use
these data to participate in and verify environ-
mental policy decisions.
The next few days will be an opportunity for
us to learn from each other. I look forward to
meeting you all during the sessions and the
breakouts and to sharing your ideas and con-
cerns.
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An Introduction to the Data
Linda A. Travers
Information Management Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
ABSTRACT
The U.S. Environmental Protection Agency has been collecting toxic chemical release informa-
tion data since 1988 on the TRI database, the first publicly accessible environmental database in
the world. TRI is also the first to cut across environmental media, providing information on
releases into the air, water, and soil and off-site transfers of toxic chemicals. Release information
is available for over 300 different chemicals and 20 chemical categories from 23,000 facilities, for
a total of over 225,000 reports from all three reporting years. TRI has been instrumental in
generating new pollution prevention initiatives by focusing attention on specific facilities and in
developing new environmental laws and regulations (including the recently passed amend-
ments to the U.S. Clean Air Act), water quality standards, and air toxics regulations in various
states. Now that three years of data are available, trends in transfers and emissions of chemicals
can be analyzed. Such information as the increases and decreases of carcinogens on a state,
county, or even facility level can be extracted to provide officials and the public with the most
complete emissions trends available.
I want to welcome you to this international
conference on the Toxics Release Inventory. I
have been involved in working on TRI now
for almost four and a half years, and I want to
share some of the lessons we have learned. We
also look forward to hearing your concerns and
issues during the breakout sessions.
My presentation will give a brief overview of
the issues that are related to data management. In
the later sessions, we will give more details about
how we built the database and all of its implica-
tions. I want to spend more time giving you il-
lustrations of how these data can be used to
challenge your thinking as you listen to the other
speakers and think about how to use this infor-
mation in your country.
One of the main points that makes the TRI
very different from any other database in the
United States is that the law specifically mandates
that data be collected and made publicly acces-
sible, which has set a precedent for information
policy in the United States. After enactment of
this law, older regulations were amended and
other laws are now being considered with similar
provisions so the public will have more access to
information.
As Mary Ellen Weber pointed out, the TRI is
the first multimedia database that contains water,
air, land, storage, and offsite information; there-
fore, it is unique. Many other databases exist in
the United States, but this is the only one explicit-
ly mandated to be publicly available.
Scope of the TRI
The scope of the program, as has been reported, is
annual. So far, we have received nearly 85,000
reports per year. Three years of the data are now
publicly available in a computer on-line system
and in many other products, such as compact
disks, diskettes, and papers. A significant amount
of data is processed each year. Each form has
about 60 data elements with a fairly large amount
9
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Reporting Releases of Toxic Chemicals
of information. We are now processing the fourth
year data, which will be publicly available in the
spring of 1992.
Currently, we receive data on 300 chemicals
and 20 chemical categories from approximately
23,000 facilities each year. One interesting statistic
is that eight industries represent about 75 percent
of those reports: paper, chemical, plastics,
primary metals, fabricated metals, electronics,
petroleum, and transportation.
These data are used by a variety of people in a
variety of ways, including
• Studies on environmental distribution,
• Mulriyear analyses,
• Geographic distribution analyses,
• Individual chemical analyses, and
• Studies on the distribution of carcinogens.
Many companies are deciding to make
dramatic voluntary reductions in their toxic
releases. Citizens are beginning to study the
releases of chemicals in their communities. Good
neighbor contracts are being established between
industry and citizens. These data are used at the
national level and the state and local level to enact
voluntary programs and write new legislation
within states. This activity has created a strong
demand for other types of analyses and informa-
tion tools. Some demonstrations during this con-
ference will show how this information can be
used with other sources, such as population data,
and in what we call geographic information sys-
tems.
Other types of analyses are being conducted
as well. Geographic distribution lets you look at
chemicals at different sites, states, and locations
that intersect with the population to give you a
better understanding of all the analyses that can
be performed.
The following figures start at an aggregated
level of information that shows distribution of
multimedia releases across the United States.
These data are often used at the national level to
target strategies for enforcement.
Trends
Now that we have three years of data, we can
start looking at trends. In Figure 1, you can see the
1987 level, which is the bar to the left, the 1988
level (the center bar), and the 1989 level, which is
the bar on the right. This information helps
people to focus questions and resources. Which
facilities reported in 1989 that did not report in
1987? Is industrial production increasing or
decreasing in an area? We are now beginning to
perform trend analyses with these TRI data.
Millions of Pounds
3,000
Air Surface Land Underground Public
Water Sewage
1987 mi 1988 E31989
Off-site
Figure 1.—Changes In releases and transfers of chemicals: 1987-89.
10
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LA. TRAVERS
Figure 2 shows the differences between the
total releases from 1988 to 1989. If you think about
this in terms of our states, you can see that a sig-
nificant number, about a third, had decreases in
toxic release inventories or transfers of greater
than one million pounds. Two states, Texas and
Louisiana, had decreases in their releases but
were still ranked first and second in overall
releases.
You can take the analysis down to another
level and look at data on the county level in the
United States. Figure 3 shows the top 100 counties
with the largest releases and transfers in 1989.
Again, the data help both the state and national
level policymakers to set priorities and focus
resources to make determinations about how they
want to work with industry to control emis-
sions.
Millions of Pounds
CD Decreases >10
EBl Decreases between 1 and 10
Figure 2.—Changes in TRI total by state: 1968-89.
Increases or Decreases <1
223.Increases between 1 and 10
Bi Increases >10
Rgure 3.—Top 100 counties for TRI total releases and transfers: 1989.
11
-------
Reporting Releases of Toxic Chemicals
You can also examine the counties that have
the most change from 1988 to 1989. Figure 4 indi-
cates the 50 counties with largest increases and
the 50 with the greatest decreases. You can begin
to make comparisons and decisions about how to
focus resources.
Figure 5 is the list of the top 10 chemicals that
were released and transferred in 1989. The black
bar is the releases and the gray bar is the transfers.
I'm sure you are familiar with many of these
chemicals.
Taking one of those chemicals, you can then
begin to examine individual trends. In Figure 6,
take a look at 1,1,1-trichloroethane (or, as we call
it, methylene chloroform), which is used as a sol-
vent in cleaning instruments for metal degreasing
and textile processing and as a pesticide in such
things as aerosols, stain repellents, and inks. This
map shows you where the chemical is being
released and transferred, by state. The black color
represents the three states where the 1,1,1-
trichloroethane is the number one chemical
released: Colorado, Vermont, and Connecticut.
CH Largest Decreases
• Largest Increases
Figure 4.—Fifty counties with the largest Increases and decreases from 1988 to 1989.
Ammonium Sulfate (solution)
Hydrochloric Acid
Methanol
Ammonia
Toluene
Sulfuric Acid
Acetone
Xylene (mixed isomers)
1,1,1-Trichloroethane
Zinc Compounds
100 200
300 400 500
Millions of Pounds
600 700 800
H3 Releases EH Transfers
Figure 5.—Top 10 chemicals with the largest release and transfer: 1989.
12
-------
LA. TRAVERS
l#1 chemical with largest total release/transfer per state
la top 10 chemical for total release/transfer per state
Rgure 6.—Releases and transfers of 1,1,1-trichloroethane.
Figure 7 illustrates how you can look at the
geographic distribution of carcinogens at a state
level. In 1989, about 123 carcinogens out of the
300 chemicals were on the list. Seven percent
(411.5 million pounds) of TRI total releases and
transfers were comprised of carcinogens. Another
interesting statistic is that 25 of those carcinogens
account for about 98 percent of the total car-
cinogen emissions.
Since the data are reported by chemical and
facility, you can then focus on which facilities are
releasing the largest amount. Individual facilities
can be targeted as candidates for cleanup action
or enforcement. The top 50 facilities accounted for
over a 100 million pounds or 26 percent of the car-
cinogen totals. Much of the emissions are in the
Texas-Louisiana area.
The TRI database allows you to continue
focusing your microscope further and further
down, analyzing multiple layers of data.
We cover 20 sectors of the manufacturing in-
dustries in the United States. Figure 8 shows the
carcinogen releases by those sectors. When you
cross the carcinogen data with the industry infor-
mation, you can see that the chemical industry
ranks first with most carcinogens released — a
total of about 135 million pounds or about 33 per-
cent of the total. The primary metals and plastic
industries rank second.
You can also examine population distribu-
tions surrounding three different TRI facilities in
a state (Fig. 9). The first facility is in a heavily
populated urban area, the second in a rural area,
and the third in a suburban neighborhood. By
using population figures, the risks versus the
population size of the surrounding areas can be
analyzed. A chemical release from traffic in high
density urban areas with heavy population can
have a different effect on health than a release
produced in a sparsely populated area. You then
can take other data and integrate them with the
TRI.
Conclusion
In conclusion, I would say that the uses of TRI are
endless. These data can be examined on a national
scale, by state, region, city, county, or by in-
dividual facility. Individual chemicals or classes
of chemicals, such as carcinogens, can be ex-
amined and analyzed for one, two, three, soon to
be four years, to look at the overall trends to
determine the overall increases or decreases.
13
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Reporting Releases of Toxic Chemicals
Millions of
Pounds
BB>25
OB 10 to 25
E3 5 to 10
CD 1 to 5
EDO to 1
Figure 7.—Total releases and transfers of carcinogens.
Industry (SIC Code)
Food (20)
Tobacco (21)
Textiles (22)
Apparel (23)
Lumber (24)
Furniture (25)
Paper (26)
Printing (27)
Chemicals (28)
Petroleum (29)
Plastics (30)
Leather (31)
Stone/Clay (32)
Primary Metals (33)
Fabr. Metals (34)
Machinery (35)
Electrical (36)
Transportation (37)
Measure/Photo. (38)
Miscellaneous (39)
Multiple codes 20-39
No codes 20-39
20 40 60 80
Millions of pounds
100
120
140
Figure 8.—Carcinogenic releases and transfers by industry: 1989.
14
-------
LA TRAVERS
Baltimore
County
Baltimore
City
Population
Density
< 10 per sq mi
< 100 per sq mi
< 1000 per sq mi
< 5000 per sq mi
> 5000 per sq mi
Howard County
Population
Estimates
Site 1Mile 4 Mile
1 16779 553583
2 5703 112619
3 3391 54335
Ann Arundel
County
Montgomery
County
Prince Georges
County
Figure 9.—Population estimates around selected TRI sites: one- and four-mile radii.
15
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f
Other Perspectives on
Toxics Release Reporting
-------
Canada's Green Plan and the
National Pollutant Release Inventory
Gordon Pope
Environment Canada
Hull, Quebec, Canada
ABSTRACT
In August of 1990, Canada adopted the Green Plan, which is a govemmentwide initiative aimed
at solving our environmental challenges effectively. This plan commits $3 billion in new funds
over six years — in addition to the $1.3 billion the government of Canada already spends an-
nually on the environment. One section in the Green Plan states that the government will
develop a national database for hazardous pollutants being released from industrial and
transportation sources. Reporting requirements for industry will be established by 1992, with
the first reports scheduled for public release no later than 1994. Environment Canada has
decided to use the U.S. Environmental Protection Agency's Toxics Release Inventory as a model,
making the necessary changes to adapt it to a Canadian context. The design of this National Pol-
lutant Release Inventory and the reporting criteria will be determined by consulting with the
provinces, territories, and other stakeholders.
We have a picture on the wall at En-
vironment Canada that shows a
young girl holding the world globe,
and although it has few words, it says a great
deal. It represents the two most important things
in our lives: our children and our environment.
There is no question at all that, if we continue
contaminating our planet at the same rate as the
past couple of decades, we will not only destroy
the quality of life, but most likely life itself. Pollu-
tion prevention has to be a top priority, and it
must transcend all political barriers, cultural dif-
ferences, and economic constraints.
Every day we wait in taking preventative
measures, we are getting two days further away
from the cure. Metaphorically speaking, we're on
a runaway train speeding downhill toward cer-
tain environmental destruction. Not only are we
polluting our air, land, and water with very
dangerous, persistent chemicals, but also by clear-
cutting our forests, destroying the protective
ozone layer, causing global warning, and using
the ocean as garbage dumps, we are destroying
the earth's natural ability to cleanse itself. We
must deter the industrial nations from their ir-
responsible polluting activities, and we must help
the developing nations jump into the 21st century
by supplying aid in the form of state-of-the-art,
pollution-eliminating technologies. Instead of
tearing around wildly, spending the taxpayers'
money on random bits of pollution control to ap-
pease the most prominent and noisiest environ-
mentalists, we must first provide some bench-
marks from which to establish meaningful con-
trols and measure the effectiveness of our work. A
release database similar to the United States'
Toxics Release Inventory (TRI) can provide these
benchmarks.
Canadian Environmental
Protection Act
Canada recognized that the issue of pollution
prevention was of prime importance and, on June
19
-------
Reporting Releases on Toxic Cfiemicals
28, 1988, the Canadian Environmental Protection
Act (CEPA) was assented to by the Canadian
government. This act gives the government
power to protect human health and the environ-
ment from the risks associated with the use of
chemicals and from exposure to toxic substances.
Under CEPA, Environment Canada is responsible
for assessing substances for their impact on the
environment and for recommending appropriate
restrictions or limits on their use to prevent harm.
Health and Welfare Canada is responsible for as-
sessing substances for their potential impact on
human health and for recommending appropriate
controls on their use. When the assessments indi-
cate a significant risk, the two departments
recommend controls or prohibitions on the use of
the substance. The government can order imme-
diate action if necessary, and controls may govern
any and all aspects of the life cycle of a toxic sub-
stance.
The regulations developed under CEPA are
designed to control toxic substances in the follow-
ing broad categories:
• Existing chemicals are defined by the
Domestic Substances List or DSL.
• Priority substances (PSL) are those existing
chemicals that must be assessed before
February 11, 1994.
• Toxic substances (or those deemed toxic
through assessment) are those existing
chemicals already scheduled in CEPA for
regulatory action.
• New substances are those that do not yet
appear on our Domestic Substances List.
Domestic Substances List
The Domestic Substance List names all the chemi-
cals used in Canada as of January 15, 1990. In-
dustries that develop new chemicals in Canada or
who import new or different chemicals have to
apply to the federal government to have them
added to the DSL and provide enough data for
their assessment by Environment Canada and
Health and Welfare Canada. This process is
designed to control chemicals used in the
Canadian environment and to prevent highly
toxic or persistent chemicals from entering the
country.
Companies were obliged to report all chemi-
cals used if they wanted them to appear on the
Domestic Substance List. Now, if a company
eliminates one of its chemicals (and happens to be
the only company reporting that chemical), then
the substance will be removed from the Domestic
Substance List and anyone wanting reinstatement
of that chemical on the Domestic Substance List
must go through the same procedure described
for new chemicals. For this reason, there was a
real incentive for the companies to make sure
they were identified as users of specific chemicals.
Priority Substances List
The Priority Substances List (PSL) (Table 1) iden-
tifies which of the approximately 21,700 substan-
ces on the Domestic Substance List most urgently
require assessment for their effect on human
health and the environment to determine if they
should be placed on the List of Toxic Substances.
A substance was selected for this list if it met at
least one of the following three criteria:
1. The substance causes or has the potential
to cause adverse effects on human health
or the environment.
2. The substance accumulates or could ac-
cumulate to significant concentrations in
air, water, soil, sediment, or tissue.
3. The substance is or may be released into
the environment in significant quantities
or concentrations.
List of Toxic Substances
Canada has a rather lengthy process for dealing
with potentially toxic substances (Fig. 1). The sub-
stance must first be identified and assessed before
a report on the technical methods of control will
be made public. If a regulation is the preferred op-
tion for controlling the substance, the regulation
is drafted. The initial draft is made public, often
through meetings that bring together groups, or-
ganizations, or persons with an interest in these
issues. The process allows public review and in-
volvement at every stage, ensures careful ex-
amination of the options, and documents the
social and economic effects of compliance. Table 2
gives the List of Toxic Substances and applicable
regulations (Schedule I, sections 13, 33 to 37).
Under the Canadian Environmental Protec-
tion Act, polluters can be fined up to $1 million a
day or more if they profited from their activities.
Corporate officials can also be punished if they
authorize or participate in activities that violate
20
-------
G.POPE
Table 1.—The Priority Substances List
GROUP 1
Arsenic and its compounds
Benzene
Effluents from pulp mills using bleaching
Hexachlorobenzene
Methyl tertiary-butyl ether
Polychlorinated dibenzodioxins
Polychlorinated dibenzofurans
Polycyclic aromatic hydrocarbons
Waste crankcase oils
GROUP2
Cadmium and its compounds
Chlorinated wastewater effluents
Chlorobenzene
Chromium and its compounds
Creosote-impregnated waste materials
Dibutyl phthalate
1,2-Dichlorobenzene
1,4-Dichlorobenzene
1,2-Dichloroethane
Dichloromethane
Di-n-octyl phthalate
bis (2-Ethylhexyl) phthalate
Inorganic fluorides
Nickel and its compounds
Pentachlorobenzene
Styrene
Tetrachlorobenzenes
1,1,2, 2-Tetrachloroethane
Tetrachloroethylene
Toluene
Trichlorobenzenes
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
GROUPS
Aniline
Benzidine
Chlorinated paraffin waxes
bis (2-Chloroethyl) ether
bis (Chloromethyl) ether
Chloromethyl methyl ether
3,3-Dichtorobenzidine
3,5-Dimethylaniline
Methyl metnacrylate
Mineral fibers
Organotin compounds (non-pesticidal uses)
About one third of the priority substances are families of
chemicals or effluents, each comprising up to several
hundred substances. Dloxlns, furans, pulp mill effluents,
arsenic, benzene, hexachlorobenzene, polycyclic
aromatic hydrocarbons (PAHs), methyl tertiary-butyl
ether, and waste crankcase oils are the nine substances
slated for earliest assessment.
ofSirtnanc* |
na to b» Toxic
ConOnu* to Monte* and
t d Control Option* }-
MMto Onto) FufeMi In
PuMe ComuftMton
ENFORCEMENT
Figure 1.—Procedure for assessing substances for
regulatory control.
this act. Anyone who is or may be affected by of-
fenses under CEPA or its regulations can seek an
injunction. Any two Canadians can petition the
minister of the environment to investigate any of-
fense.
The Green Plan
In December 1990, the Canadian federal govern-
ment launched its environmental action plan —
the Green Plan. The most important environmen-
tal action plan ever produced in Canada, it is the
source for more than 100 important and well-
funded initiatives over the next six years and a
comprehensive plan that deals with the environ-
ment as interrelated and whole. In addition to the
$1.3 billion Canada already spends annually on
the environment, the Green Plan commits an ad-
ditional $3 billion in new funds over six years
(Table 3).
The Green Plan provides definite targets and
schedules that will drive environmental initia-
tives within federal jurisdictions for years to come
and will form the basis on which Canadians can
judge our overall performance. This plan has im-
plications to go beyond Canada's borders. The
tools we develop and programs we implement
will make a contribution to global environmental
health in this critical decade of the 1990s.
21
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Reporting Releases on Toxic Chemicals
Table 2.—List of Toxic Substances—Schedule I (sections 13, 33 to 37).
COLUMN I
NAME OR DESCRIPTION OF SUBSTANCE
COLUMN II
TYPE OF REGULATION APPLICABLE
Chlorobiphenyls that have the molecular Ci2Hio-nCln
in which "n" is greater than 2
(a) Prohibited commercial, manufacturing, or processing uses
(b) Maximum concentrations in products
(c) Maximum quantities and concentrations that may be
released into the environment
Dodecachloropentacyclo [S.S.O.O2'6^3'9."418] decane
Prohibited commercial, manufacturing, or processing uses
Polybrominated biphenyls that have the molecular
formula Ci2Hio-nBrn in which "n" is greater than 2
Prohibited commercial, manufacturing, or processing uses
Chlorofluorocarbon: totally halogenated
chlorofluorocarbons that have the molecular formula
CnClxF(2n + -x)
Prohibited commercial, manufacturing, or processing uses
Polychlorinated terphenyls that have a molecular
formula CisHu-nCIn in which "n" is greater than 2
Prohibited commercial, manufacturing, or processing uses
Asbestos
Lead
Mercury
Vinyl chloride
Limited atmospheric releases from asbestos mines and mills
Limited atmospheric releases from secondary lead smelters
Umited atmospheric releases from chlor-alkali mercury plants
Limited atmospheric releases from vinyl chloride and
polyvinyl chloride plants
Table 3.—Green Plan resources (over six years).
I Life's Three Essentials: Clean Air, $850 million
Water, and Land
II. Sustaining Our Renewable Resources
III. Our Special Spaces and Species
IV. Canada's Unique Stewardship: The
Arctic
V. Global Environmental Security
VI. Environmentally Responsible
Decisionmaking
VII. Starting in Our Own House
VIU.Emergency Preparedness
TOTAL
$350 million
$175 million
$100 million
$575 million
$500 million
$275 million
$175 million
$3 billion
Two major themes are woven throughout the
Green Plan: sustainable development and the
benefit of partnerships. Sustainable development
is described, in general, as activity in which the
environment is fully incorporated into the
economic decisionmaking process as a fore-
thought, not an afterthought. It holds that resour-
ces must be treated on the basis of their future as
well as present value. That approach offers
genuine hope of economic development without
environmental decline.
This plan was born out of an extensive na-
tional multi-stakeholder consultation process: 41
information sessions and 17 consultation sessions
were held in towns and cities from coast to coast.
The process culminated in 1990 with a two-day
national wrap-up session in Ottawa.
The Green Plan represents the unique efforts
and commitment of men and women of Canada
from every sector of society working together, as
partners, in national environmental decisionmak-
ing. Clearly, only by strengthening existing
partnerships (such as those developed and
solidified during the Green Plan consultation
process) and by forming new partnerships will
we truly achieve sustainable development.
The National Pollutant Release
Inventory
One section of the Green Plan calls for Canada "to
develop a better understanding of the nature and
quantity of toxic substances being released in
Canada," and to this end, "the government will
develop a national database for hazardous pol-
lutants being released from industrial and
transportation sources." It also states that "the
reporting requirements for industry will be estab-
lished by 1992 with the first report scheduled for
public release by the end of 1994."
22
-------
G.POPE
We were very impressed with the work done
by the U.S. Environmental Protection Agency
(EPA) and decided that Canada's database, which
will be called the National Pollutant Release In-
ventory (NPRI), will be modeled after the Toxics
Release'Inventory (TRI). To obtain the maximum
amount of exposure and public or industry input
during the development of its NPRI, Canada has
again decided to use a nationwide multi-
stakeholder consultation process to determine the
details of the reporting format.
We visited EPA's facilities in Washington,
D.C., and were given detailed presentations on
the different activities involved in collecting, com-
piling, and publishing release data. TRI's list of
chemicals has remained basically unchanged
since the program was started and only a few
data handling procedures have been modified
slightly. Although we're just beginning to work
on Canada's National Pollutant Release Inven-
tory, we will benefit tremendously from EPA's ex-
periences with its TRI.
However, the structure of Canada's NPRI will
differ from the United States' TRI. In the United
States, Congress specified several of the param-
eters of the TRI, including the industrial sectors
from which the reports would be obtained, the list
of chemicals, and the threshold reporting limits.
Initially, about 320 chemicals and 20 chemical
categories were specified for investigation, and
only industrial facilities with activities falling
within the U.S. Standard Industrial Classification
(SIC) codes 20 to 39 were required to report. The
threshold reporting requirements for chemical
use were specified at 75,000 and 50,000 pounds
for the first two years, respectively, and then were
fixed at 25,000 pounds starting in the third year.
If we look at the same group of industries in
Canada and set our threshold reporting criteria at
10,000 kilograms (22,000 pounds) instead of the
United States' 25,000 pounds, then we can expect
to receive close to 2,000 reports. This compares to
about 85,000 reports collected by EPA in 1990.
In trying to estimate the expected number of
reports in Canada, we compared the Domestic
Substances List to the chemicals covered by the
TRI and discovered that only about half (160) of
these chemicals show up in Canada. Not only
were the companies asked to identify specific
chemicals for the Domestic Substance List, but
also they had to indicate a usage range for the dif-
ferent chemicals. Figure 2 shows the number of
900
800
700
600
500
400
300
200 -
100
744
LEGEND
A - < 100 kg
B - 100 to 1,000 kg
C - 1,000 to 10,000 kg
D - 10,000 to 100,000 kg
E - 100,000 to 1,000,000 kg
F - 1,000,000 to 10,000,000 kg
G - over 10,000,000 Kg
143
A B C D E F
QUANTITY PROCESSED/USED/IMPORTED
Figure 2.—Domestic Substances List records showing number of reports In different categories.
G
H
23
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Reporting Releases on Toxic Chemicals
LEGEND
A""-"">' 0 kgs
B - > TOO kgs
C - > T.OOO Kgs
D - > 10,000 kgs
- •••> 100,000 kgs
F - >t,OOO.OOO kgs
Q- > 10,000,000 kgs
B C D E F
QUANTITY PROCESSED/USED/IMPORTED
Figure 3.—Number of reports for TRI chemicals found in Canada.
facilities reporting in the different categories. Fig-
ure 3 illustrates the total number of reports versus
different threshold reporting criteria.
We assumed that all quantities reported were
equal to the median of their respective groups
and produced Figure 4, which shows the ex-
pected percentage of release data captured versus
an increasing threshold reporting criteria. As
mentioned above, we intend to use a reporting
threshold of 10,000 kilograms, which, as you can
see from this last graph, will enable us to obtain
reports on a high percentage of the total releases.
In spite of the fact that we are required to col-
lect data from the transportation sector, as
specified in the Green Plan, we will still have a
relatively low number of reports to process and
therefore will be able to look at a broader list of
chemicals or other industrial sectors, such as min-
ing, agriculture, or forestry.
Setting Up the NPRI
In trying to take advantage of the consultation
process, an initial scoping was held with a limited
number of stakeholders from various sectors. At
this meeting, we decided that the best way to
proceed would be to form a steering committee of
15 to 20 members made up of representatives of
stakeholder groups, such as health, industry, en-
vironmentalists, and labor. Their mandate is to
advise and assist in the development of the essen-
tial information and analysis necessary to set up
Canada's National Pollutant Release Inventory
and identify any varying opinions among the
stakeholders regarding the design of this NPRI.
This steering committee will meet about five
times over the course of 1992 and, if necessary,
will designate smaller working groups to deal
with specific issues. During this consultation
process, a series of nationwide information ses-
sions will be held to present the NPRI work to the
stakeholders. Following the information sessions
and most of the steering committee meetings, one
or two consultation workshops will be held
where the stakeholders can discuss the design of
the NPRI. At these meetings, stakeholders will be
asked to validate the steering committee's recom-
mendations and try to resolve any outstanding is-
sues. Associations and networks will be invited to
select participants to represent them at the
workshop.
24
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G. POPE
120%
110%
100%^
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
-#-
-*-
LEGEND
A - > 0 kgs
B --> 1OO kgs
C - > 1,000 kgs
0 - > 10,000 kgs
E - > 100,000 kgs
F - > 1,000,000 kgs
Q - > 10,000,000 kgs
H - >...26,000.000 kgs
B C D E F G
QUANTITY PROCESSED/USED/IMPORTED
H
BASED ON taae DATA
Figure 4.—Data collection effectiveness.
As a starting point, we will use TRI with very
few modifications and present this to the commit-
tee for their consideration. We fully expect that
our steering committee will recommend that we
add other chemical substances to the TRI list and
expand into other industrial sectors with our
reporting requirements.
We are presently mailing information on the
NPRI to about 1,800 environmental and 100 in-
dustrial associations. We also will try to contact as
many of the industries as possible that may be re-
quired to report under the NPRI requirements.
We hope to take advantage of the work done by
EPA on its Toxics Release Inventory.
Conclusion
I would like to stress the importance of having a
database like TRI. It is a tool that can be used as a
pointer to identify hotspots or areas that merit
our attention or as a benchmark or reference point
for further investigation or regulation. Environ-
mental agencies and public interest groups can
use the data to encourage facilities to cut back on
pollutant releases. These data will be used to help
reduce toxic emissions and, in Canada's case,
help implement our Green Plan goal of a healthy
environment and a sound, prosperous economy.
25
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A Public Interest Group Perspective
Gerald V. Poje
Green Seal
Washington, D.C.
ABSTRACT
In the information age, gathering and sharing data can be a powerful incentive for environmen-
tal improvement. Since 1988, the Toxics Release Inventory has altered American business,
government, and public perceptions of toxic emissions. Armed with a ready-made, multimedia
schedule of high priority chemicals and emission points, corporations, EPA, and state agencies
have pursued a new pollution prevention agenda. Public and private partnerships, such as the
33/50 project, seek accelerated emissions reductions by using this national toxic chemical ac-
counting system. States have approved toxics-use reduction audits and created pollution
prevention institutes. Congress has passed additional toxic information provisions through the
Pollution Prevention Act of 1990, and a Right-to-Know-More proposal now awaits debate before
the current session.
Introduction
In September 1990, an international conference
convened in Veszprem, Hungary, to discuss emer-
gency planning for, response to, and prevention
of chemical accidents. At that meeting, non-
governmental organizations met in a side session
to develop a policy dealing with chemical infor-
mation. Representatives from Bulgaria, Czechos-
lovakia, Germany, Hungary, Italy, Poland,
Romania, the United States, the Soviet Union, and
Yugoslavia later signed the 10-point agreement
(Table 1) that focused on every citizen's right to be
notified about and gather verified information on
chemical substances, including quantities
processed, stored, and used; specific management
of these substances; effects to health and environ-
ment; accidents involving these chemical substan-
ces; routine emissions; and waste production
from privately and government-controlled in-
dustrial activities.
These broad-based positions are held by
many people operating in the public interest who
are trying to alleviate chemical contamination
around the globe. In the United States, the Toxics
Release Inventory (TRI) has been key to mobiliz-
ing enormous public interest about toxic chemical
problems.
Background
In the mid-1970s and on into the early 1980s,
numerous abandoned hazardous waste sites were
polluting communities across the United States.
The resulting problems stimulated Congress to
address this issue and, in 1980, it passed the Su-
perfund Law, which created a fund to assist in the
cleanup of these abandoned waste sites. By the
end of the five-year term of that federal statute,
the enormous groundswell of public dissatisfac-
tion with the pace of the cleanup provoked Con-
gress to revise the Superfund Law in 1986.
However, that reauthorization was informed
by other events. Most notably, in 1984, the news
of the tragic chemical release in Bhopal, India,
had struck home in the United States, as inves-
tigations took place to find out how American
27
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Reporting Releases of Toxic Chemicals
Table 1.—The Veszprem Declaration (September 1990).
Signatories resolved to:
I. Emphasize the principle that every citizen has both the need to have information about potential accidents for preventing
their consequences and the right to have information for participation in democratic decisionmaking, and
II. Demand in accordance with the charter on Environmental Rights and Obligations of Individual Groups and Organizations
that the governments of participating nations guarantee that:
1. Every citizen has the right to be notified about and to gather verified information about chemical substances (including
radioactive materials), quantities processed, stored and used, specific management of these substances, effects to
health and the environment of these substances, accidents involving these substances, routine emissions and waste
production from private and government-controlled industrial activities.
2. Every citizen has the right to participate in emergency planning, specifically including rights of access to all hazard
assessments and other information defining the potential for accidents and subsequent impacts upon workers and
communities attributabel to these industrial activities and technologies and management of these risks. Emergency
planning is an essential part of land use planning, and must be considered in the conception, design, construction, and
operation of industrial facilities.
3. Every citizen has the right to participate in all licensing procedures which permit activities involving these chemical
substances.
4. Licenses must be amended whenever technological innovations to reduce specific risks become available.
5. Industries and governments which create public risks associated with chemical activities must assure the public that
progress is being made toward technological innovations that reduce these risks.
6. Citizen rights to be notified, to gather information, and to participate in licensing shall not be limited by national
boundaries.
7. Every citizen has the responsiblity to utilize these rights of notification and public participation to assure
environmental protection. Environmental protection is defined by activities which sustain the air, the water, the soil, and
thereby nurture biological diversity.
8. At this moment of human endeavor, technological innovation must not only reduce the acute and chronic risks to
public health and the environment in and of itself, but actually improve currently degraded environmental quality.
9. Every citizen has the right to employ technical experts of their choice to review technological information.
10. Nations of the European Community, the United States, and other economically advantaged nations through fees
assessed upon activities threatening public health and the environment should support the growth and development of
non-governmental organizations because they strengthen democratic values by providing public reassurance of
progress toward environmental protection.
facilities of the Union Carbide Corporation were
managing methyl isocyanate. It is important to
understand that, when the gas escaped, very little
information was publicly available about this
chemical. Not until seven years later did the Jour-
nal of the American Medical Association publish a
report documenting important lexicological in-
formation on methyl isocyanate, and only in 1991
did Union Carbide make a legal settlement
toward restitution to the community most
damaged by that chemical accident.
The Emergency Planning and Community
Right-to-Know Act (Title III of the Superfund
Amendments Reauthorization Act of 1986), the
most significant federal United States' public
policy on toxic emissions, was promulgated
within this political context (Table 2). This public
policy deals with chemical accidents and public
rights of access to data on chemicals in their com-
munity.
This conference focuses on the issues sur-
rounding the fourth point of Title III policy: col-
lecting data on release of toxics and making it
Table 2.—Major Provisions of the United States
Emergency Planning and Community Right-to-
Know Act.
1. Emergency Planning Requirements
2. Emergency Notification and Follow-up Notification
after an accident
3. Right-to-Know Requirements about Possible
Catastrophic Releases
4. Right-to-Know Requirements about Routine Releases
available to the public. However, those interested
in Right-to-Know policy shouldn't lose sight of
the first three points in which Congress required
industry, the U.S. Environmental Protection
Agency (EPA), and the public not only to know
about the potential for accidents in their com-
munity but also to actively gather information
about accidents and develop plans to prevent
them. The 1990 amendments to the United States
Clean Air Act will expand public access to
detailed hazard assessments of industrial facilities
handling extremely dangerous chemicals.
28
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G.V. POJE
Other portions of the Right-to-Know Act that
provide access to additional information, such as
material safety data sheets, build upon this right
for people in the workplace and expand it to the
public at large. In addition, the act includes
provisions for inventories or data about the hous-
ing, amounts, and types of hazardous chemicals
being stored at industrial facilities and accidental
and annual releases into air, water, and soil. With
the Toxics Release Inventory, for the first time,
Americans possessed multimedia, annual snap-
shots of the flow of toxic chemicals into the sur-
rounding environment.
The Toxics Release Inventory
The TRI is a geographically based data set that
identifies releases of carcinogenic and other haz-
ardous chemicals to the environment. TRI data
are incorporated into an annual report on these
300-plus chemicals and their emissions to air
(both fugitive emissions as well as those from
smokestacks), water, land, and waste sent to off-
site facilities.
In 1987, one immediate focus of the TRI was
on the chemicals' effect on plants and animals.
EPA developed health effects information to aug-
ment the TRI, a good part of which deals with car-
cinogenic chemicals. Cancer is a disease of
developed nations, and the United States has
devoted many resources to combating it. During
our history of testing chemicals for car-
cinogenirity, Americans have standardized
lexicological evaluation and risk characterization,
and therefore, data on the many chemicals that
can cause cancer.
However, scientists in the United States are
just beginning to understand the impacts of toxic
chemicals on other systems. In July 1991, a major
conference was held at the Wingspread Facility in
Racine, Wisconsin, that addressed another aspect
of toxic chemicals — their ability to interrupt nor-
mal sexual development of organisms. This con-
cern was stimulated by environmental problems
in the Great Lakes that have become widely
known and feared. Some widely used chemicals
are known to operate as hormonal disrupters.
Depending upon the organism's stage of develop-
ment, ingestion of these chemicals can produce
dire consequences that may be observed only at
the point of sexual maturation when organisms
are no longer capable of carrying on normal
reproduction. These data parallel fieldwork car-
ried out in the Great Lakes that indicate a massive
collapse in certain wildlife populations, par-
ticularly those dependent upon fisheries.
While information on health effects is impor-
tant, TRI data have had impacts in other ways. On
June 30, 1988, the day before the first release of
the TRI data set, Richard Mahoney, the chief ex-
ecutive officer of Monsanto Company, made a
bold announcement. He announced that, within
four years, Monsanto would reduce by 90 percent
its airborne emissions of toxic chemicals
worldwide. This change in policy has set off a
rush of activities toward pollution prevention.
American public interest groups use TRI data
from one part of the country to influence policy
and regulations under a different federal environ-
mental statute. For example, Clean Water Action
examined data on releases to water discharges in
the Houston Ship Channel, an important in-
dustrial area of the United States that has received
large amounts of industrial effluents. It used that
information to designate the channel as a toxic
hotspot, an area that requires a much higher de-
gree of public investigation and regulatory rigor.
Chemical contamination is now ripping holes
in the stratospheric ozone layer, producing an in-
flux of ultraviolet radiation that some predict will
result in millions of incidences of skin cancer over
the next'several decades. These data have caused
global alarm and concern. Public interest groups,
such as the Silicon Valley Toxics Coalition, are
using TRI information in the United States to ac-
celerate the schedule for reducing those particular
chemical emissions as well as their usage.
Many people thought that the TRI would
spur public debate about risk assessment. How-
ever, the center of debate has focused on pollution
prevention — determining the process by which
industry causes emissions. The TRI has identified
opportunities for people to choose
• chemical and product substitution,
• process modifications,
• on-site dosed processed recycling, or
• improved housekeeping at facilities
to change the way chemicals are being used and
reduce pollution at the source rather than control
it at the end.
Public interest groups have also used the
citizen suit provisions of TRI to promote pollu-
tion prevention and education. In 1990, the Atlan-
tic States Legal Foundation reached a $68,000
settlement with Murray Sandblast and Paint
29
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Reporting Releases of Toxic Chemicals
Company in Buffalo, New York. Under the citizen
suit provisions of the Right-to-Know Act, the
foundation discovered that Murray Sandblast had
failed to report information to the public, so it
took the company to court, sued it, and settled
outside of court. That settlement required the
company to hire a pollution prevention expert to
review its processes and reduce the toll on the en-
vironment. The foundation also set up confer-
ences to educate citizens about this information
statute.
Why does the TRI work? Among the many
reasons, two are key. First, the information must
be made publicly available in a computer-acces-
sible data format — a revolutionary piece of
public policy in the United States. Equally impor-
tant are TRI's trade secrecy provisions. In 1976,
the Toxic Substances Control Act was passed, but
it has not been able to accelerate the growth of
clean technologies, partly because of trade
secrecy. Under TRI provisions, it is extremely
onerous for industry to claim frivolously that it
cannot disclose information. During the first year,
fewer than 40 claims of trade secrecy were al-
lowed for more than 78,000 different TRI reports.
That's a real measure of TRI's success.
Future Uses of the TRI
A next step for Right-to-Know will be integration
of the TRI data with other statutes and provisions
of law as well as expansion of the Right-to-Know
Act beyond this current statute.
One focus of integration will be to improve
the protection of public drinking water supplies.
Using the Graphic Exposure Modelling program
and TRI data, EPA's Office of Toxic Substances
will allow concerned citizens to locate their
source of public drinking water and identify an-
nual toxic discharges from upstream industrial
facilities.
Today, American environmentalists are pro-
posing a new law — the Right-to-Know-More
legislation. This proposal would expand TRI's
focus by increasing data about additional chemi-
cals that could be released accidentally and ex-
panding the right-to-know to include additional
facilities. The Right-to-Know-More legislation
would include data on all facilities that handle
toxic chemicals.
The TRI is our annual snapshot. To propose
explicit pollution prevention prescriptions, in-
dustrial facilities must be characterized far better
than is done currently. Therefore, the public inter-
est community seeks to include a maximum hour-
ly rate of release to air, water, and soil and a
description of the causes, source, and frequency
of these maximum hourly releases of toxic chemi-
cals, to set a much higher priority list for pollu-
tion prevention or clean technologies — and to
keep the public focused on that issue.
One of the TRI's failures is that it avoids look-
ing at many important chemicals, such as pes-
ticides. Each year in the United States, nearly two
billion pounds of pesticides are applied to the
landscape. Put that into the perspective of 5.7 bil-
lion pounds of chemicals identified as the annual
TRI emissions inventory for 1989 and you can see
that TRI misses a major segment of toxic loading.
Pesticide production in the United States has in-
creased at an alarming rate: almost 2.5 billion
pounds of active pesticides are being produced
yearly. Conventional practices — agricultural
(both on fields and crop systems), industrial ap-
plications, and home applications — amount to
almost 1.1 billion pounds. The wood preservative
industry uses a billion pounds of those chemicals.
These are just the active ingredients; in the
United States, we describe the carriers for active
ingredients as "inert ingredients" — a misnomer
because those chemicals can be the same toxic
chemicals identified under TRI as solvents.
Other cross-cutting issues involve boundary
areas. The United States and Canada are studying
the Great Lakes, which form an important liquid
boundary between those two nations. The Inter-
national Joint Commission that governs those
waterbodies has established a scientific task force
to investigate persistent pollutant problems in the
Great Lakes Basin. This commission has called for
virtual elimination of persistent chlorinated
chemicals as well as toxic metals. Their report on
virtual elimination recommends asking the
countries and states that govern the Great Lakes
to establish a sunset task force for some of the
worst and most pervasive chemical problems.
One recommendation was to investigate every
use of chlorine by January 1, 1993, and issue a
time schedule to eliminate this chemical in paper
and pulp bleaching processes. Around the globe,
environmentalists have accelerated interest in
chlorine chemistry and challenges its rampant
use, which has led to some persistent chemical
problems.
The Veszprem Agreement declared that
"citizen rights to be notified, gather information,
and participate in licensing shall not be limited by
30
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national boundaries." A Canadian group, Pollu-
tion Probe, has aggressively tracked toxics release
inventories along the borders of the Great Lakes.
Any consideration of computer-accessible
databases within Europe must take into account
movement of materials across borders and the
vested interest that communities downwind and
downstream have in understanding that process.
A final cross-cutting emergent issue deals
with another major missing element in this
release inventory — the loading of toxic chemi-
cals into products for the home. All over the
United States, communities are deciding how to
deal with municipal waste. Should they bury gar-
bage in landfills or incinerate it, and what hap-
pens if they do? What would complex mixtures of
plastics and remains of liquid household solvents
do to the environment around a landfill? In a na-
tion where its use is widespread, many environ-
mental groups are challenging the use of
polyvinyl chloride packaging. TRI has prompted
many Americans to think not just about the point
of production but also about the justification of
product lines. Currently, more Europeans think
about a cradle-to-grave life cycle analysis of
products than Amer-icans. They are concerned
not only about production points and consump-
tion of resources at that point of production but
also the implications when products are used in
households as well as disposed by municipalities.
Conclusion
Mismanagement of toxic chemicals and hazard-
ous waste threatens environmental health and
G.V. POJE
economic security. The increasing amount of
chemical emissions and waste production is truly
alarming. Existing and potential impacts of toxic
chemicals on the environment and public health
are monumental. Fish poisoned through ac-
cumulations of persistent PCBs and pesticides are
now injuring humans and other species in the
Great Lakes; in the United States, more than
20,000 serious hazardous waste sites require ex-
pensive cleanups; and the world's stratospheric
ozone layer has become eroded from wasteful
uses of halogenated compounds. Inefficient
chemical management consumes scarce industrial
and governmental resources that could otherwise
be devoted toward improving industrial competi-
tiveness and resolving other pressing economic
and environmental issues.
Pollution prevention is the key to solving the
toxic threat. Pollution prevention means source
reduction: any practice that reduces the amount
of any hazardous substance, pollutant, or con-
taminant entering any product or waste stream
before recycling, treatment, or disposal. Pollution
prevention is a public responsibility.
In the United States, TRI has raised the level
of public debate about chemical consumption
patterns of Americans and promoted pollution
prevention. Every world citizen has a stake in in-
creasing the scope and pace of this debate around
the globe. One start would be expansion of
publicly accessible multimedia emissions and
usage databases.
31
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An Industry Perspective on Reporting
Releases of Toxic Chemicals
Elizabeth A. Fisher
Air and SARA Programs
Rohm and Haas Company
Philadelphia, Pennsylvania
ABSTRACT
The Toxics Release Inventory has created a valuable accounting system for emissions from
selected facilities in the United States. These publicly available data have prompted companies
to voluntarily set priorities and establish emissions reductions goals. The Emergency Planning
and Community Right-to-Know Act is an excellent starting point, but it is not without problems.
Care must be taken to use the Toxics Release Inventory appropriately, on a sound scientific basis,
and set priorities to improve these data.
Introduction
The Emergency Planning and Community Right-
to-Know Act (EPCRA) is a valuable law. For the
first time, certain industrial manufacturers are re-
quired to quantify and publicly announce emis-
sions of specific chemicals, including releases to
the environment and shipments of waste to off-
site facilities for treatment, storage, or disposal.
These manufacturers must submit a Toxic Chemi-
cal Release Inventory (TRI) report to the U.S. En-
vironmental Protection Agency (EPA) every year.
EPA then compiles that information into a nation-
al computerized database that is publicly acces-
sible in libraries, at governmental offices, and
on-line through a computer. The manufacturer's
efforts to compile data and the use of this infor-
mation by manufacturers, regulatory agencies,
and the public have been generally beneficial. The
system is imperfect; it can be misused, but its
mere existence has revolutionized environmental
reporting.
TRI's Uses
Investigation and Measurement
Even without public accessibility, determining the
total releases and transfers for a plant's toxics
chemical release inventory is useful. For the first
time, engineers have had to scrutinize their
processes as a whole and quantify wastes released
to all media. As an investigative and measure-
ment tool, this multimedia inventory has helped
provide a baseline of certain toxics releases and,
hi some cases, has revealed valuable information
for process improvements that otherwise might
not have received adequate attention.
Planning
As a planning tool, the TRI provides manufac-
turers with an excellent base to determine
priorities for improvement and offers a starting
33
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Reporting Releases of Toxic Chemicals
point on which to build other programs and set
goals within a production facility. After a facility
determines the amount of emissions and compiles
data, progress toward an emissions reduction
goal can be quantified, measured, and compared.
Over the four years that Toxics Release Inven-
tories have been required, individual facilities
have used these data to improve their processes
and operations. Progress is evident. Manufac-
turers have achieved emissions reductions, and
downward trends in combined emissions have
been reported yearly.
Communication
The TRI is also an excellent communication tool.
Within a plant, the tremendous effort to put
together data from numerous sources and depart-
ments has made every employee aware of toxic
emissions. Public availability of the data and pub-
lication of numerous analytical reports have
made many Americans, including industrial
workers, regulators, private citizens, and special
interest groups, more aware of emissions. Some
companies have set up Community Advisory
Councils to disseminate information on releases
and the effects of chemicals.
A relatively concise tool, the TRI is a national-
ly uniform source of information about the quan-
tities of and trends in chemical emissions from
individual and various groups of facilities; data
are available by industry, state, release, or chemi-
cal type.
Because EPCRA focuses on the community's
right-to-know and not just the plant's compliance
with environmental regulations, many jobs now
focus on accommodating the community's infor-
mation needs and concerns. Plant and environ-
mental managers, even operators and plant
engineers, now spend more time communicating
with the public about emissions and operations, a
change from past years when the plant or the
technical community was the foremost focus. By
hearing about citizens' concerns firsthand,
manufacturers have realized that just making a
good product is not enough. Being responsive to
citizen concerns and communicating to make the
public feel comfortable with plant operations has
changed the way manufacturers do business.
Initiating Other Programs
The TRI has also acted as a catalyst to initiate
other programs and trends. Without any
regulatory pressure, many companies have
volunteered to set emissions reduction goals,
which vary for each company but range from
Monsanto's plan (the first company to publicly
announce a goal) to reduce toxic U.S. air emis-
sions by 90 percent by 1992, to Hoescht's decision
to stop underground injection of wastes com-
pletely, to Union Carbide's goal of reducing am-
bient toxic air concentrations to 1/1000 of the
workplace standard, to Rohm and Haas'
worldwide objective — to reduce its TRI air emis-
sions 75 percent by 1996. Reduction levels range
from 20 to 100 percent; target goal years range
from 1991 to 2000 to "ultimately"; some goals ad-
dress only carcinogens or CFCs, others address all
waste; some goals are worldwide, others are U.S.
only — but all will result in improvements that
might not have been made if the TRI were not
available.
Building on industry's initiative, the EPA has
developed the 33/50 program, also known as the
Industrial Toxics Project. A voluntary reduction
program, 33/50 includes more than 200 of the
companies invited to commit to reducing national
aggregate emissions of 17 toxic chemicals from
the 1988 TRI levels 33 percent by the end of 1992
and 50 percent by the end of 1995. These 17
chemicals were selected because they are released
into the environment in large quantities or are
toxic or hazardous pollutants and because the
releases might be reduced through pollution
prevention practices.
Some companies have already extended TRI-
type reporting worldwide. Others have included
additional chemicals in their inventories that may
be present at a particular plant but are not toxic or
not prevalent enough to merit inclusion in EPA's
national database. Some companies have tried to
determine the impact of their releases on sur-
rounding communities by estimating ground-
level concentrations of air emissions on a
case-by-case basis. Facilities can use data ap-
propriately for their unique situations to assess
impacts on their local community. Employing the
same impact analysis for all facilities nationwide
would be a misuse of that data.
Partly because of the initiatives that came out
of the TRI program, voluntary programs are
being tested for other laws and regulations. More
effective emissions reductions can often be
achieved than with the old "command and con-
trol" strategy of past legislation and regulations.
The Clean Air Act Amendments of 1990 include
an Early Reduction Program: sources that achieve
34
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E.A. flSHK?
an early 90 percent reduction from 1987 air emis-
sions levels can be granted a six-year extension
from the potentially more stringent standards for
control that will soon be required. The regulatory
reform agenda encourages cooperative and in-
clusive implementation, flexibility in regulations,
and use of regulatory negotiations and
roundtable discussions to address the concerns of
all interested parties, including the regulated
community, special interest groups, and
regulators, during development of regulations.
Numerous voluntary goals committed to by a
variety of companies show that effective reduc-
tions can be made without a command from EPA
to install pollution control devices.
TRI's Drawbacks
Burdensome Reporting
The reporting itself and addressing the issues that
result from reporting are a tremendous burden,
although the benefits seem to outweigh the
problems. Fortunately, many companies find that
generating emissions inventories for the TRI
broadens employees' knowledge, organizes
process information, improves communication
and awareness, and reveals areas for process and
product improvement. Many companies employ
at least one person whose sole job is to read and
interpret TRI regulations, guidances, notices, in-
terpretations, and bulletins; participate in training
courses and meetings about TRI; and facilitate
reporting from the company's regulated facilities.
Some companies develop calculation and internal
guidance manuals, provide in-house training ses-
sions every year, and set up extensive databases
to handle the tremendous quantity of information
generated to fulfill the reporting requirements.
Staff at each facility must understand the regula-
tions and communicate these standards to
employees who identify emissions points and
measure emissions.
To calculate pounds of emissions, staff tap
data from numerous sources, including
• safety / health / environmental / ambient
monitoring or stack tests,
• design specifications,
• operating instructions,
• basic chemistry/engineering/biology prin-
ciples,
• accounting records,
• inventories,
• production records,
• raw material and product lists,
• upset or spill reports,
• licenses and permits,
• waste manifests,
• material safety data sheets,
• operating logs,
• compliance reports,
• performance tests, and
• process flowsheets.
Emissions determinations must be verified,
documented, and defensible. Even the determina-
tion of whether a facility or chemical meets the
reporting threshold or de minimis limits for in-
clusion in the calculations can be a major task. For
the first year of reporting, the 13 Rohm and Haas
manufacturing facilities and their corporate staff
spent approximately $200,000 for monitoring and
consulting and 7,000 hours to prepare TRI data.
The burden has not changed much over the years.
The TRI is a massive, complicated, and intricate
program and database. Efforts to improve data
quality are ongoing. Changes are continually
being made to Rohm and Haas' operations and
staff as well as to EPA's TRI program, so addition-
al training-is required.
Incomplete Representation of Toxic
Chemical Releases
The TRI program and database, while called the
national Toxics Release Inventory, does not repre-
sent all releases of toxic chemicals in the United
States, nor does the TRI list of chemicals include
all of the toxics released. In addition, not all of the
chemicals on the list are toxic; some are there be-
cause companies use large amounts of these sub-
stances or because these chemicals affect the
environment. The Congressional Office of Tech-
nology Assessment estimates that the TRI data
represent only a portion of total toxic chemical
releases to the environment.
Only manufacturers are required to report;
however, processors and other users of chemicals
emit toxics as well. (Automobiles are the major
source of toxic emissions in the outdoor air we
breathe. However, most exposures to toxic air
emissions originate from products used indoors.)
Lastly, the General Accounting Office estimates
that almost one-third of those manufacturers
covered by the regulation have not filed the re-
quired reports.
35
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Reporting Releases of Toxic Chemicals
Misrepresentation of Off-site
Transfers as Emissions
The TRI defines emissions as "releases to the en-
vironment and transfers to off-site facilities."
Usually, the materials transferred to off-site
facilities are treated further and rarely released to
the environment.
• Organics can be degraded by bacteria in
publicly owned treatment works (POTWs)
or by incineration.
• Acids and bases can be neutralized to com-
mon salts.
• Ammonium sulfate, which accounts for the
highest quantity of transfers to POTWs, is a
form of fertilizer.
• Methanol, the second highest quantity of
transfers, is decomposed by bacteria into
carbon dioxide and water.
Transfers to off-site treatment or recycling
facilities cannot be equated with environmental
releases, especially if these data are used to
evaluate or represent effects on human health and
the environment. Therefore, the total TRI emis-
sions represent some quantity between total
waste generated and total emissions to the en-
vironment. Unfortunately, because a distinction is
not made when releases and transfers are entered
in the emissions database, the common usage
definition of emission is applied to transfers as
well. This practice interferes with setting ap-
propriate priorities for release or risk reduction
and forces goal setting to an intermediate step
where achievement may have no effect on the
quantity of chemicals released to the environ-
ment.
Diversion Away from Risk Reduction
The TRI includes only total pounds of emissions
of certain chemicals, with an emphasis on reduc-
ing pounds of chemical emissions. No ranking ex-
ists to distinguish high from low toxicity
chemicals on the list, nor can exposure be as-
sessed on a national level to determine risk.
Generally, the highest quantity of chemicals
emitted have the lowest toxicity because the focus
has been on reducing emissions of high toxicity
chemicals.
Pounds are the unit of measure in the nation-
al database; therefore, industries focus on reduc-
tions in pounds and set different priorities than if
they focused on reducing risk. For any given
chemical, risk can be reduced by lowering emis-
sions if the public is exposed to the chemical. But
to lower risks from a variety of chemicals, toxicity
and exposure are as important as pounds emitted.
In addition, reducing the amount of chemicals
sent for off-site treatment that converts organic
materials to carbon dioxide and water or burns
them for energy recovery will minimally reduce
risk in comparison to similar reductions in actual
releases to the air, water, or land. In fact, if coal is
burned in place of a dean waste organic stream,
risks increase from ensuing emissions of lead,
mercury, nitrogen oxides, and sulfur oxides.
Right-to-Understand Problems
The public has a right to know and also a right to
understand. Improvements in education and
communications are needed to inform the public,
legislators, regulators, regulated communities,
and special interest groups who make the policy
decisions. Laws or programs based on a mis-
guided premise do not solve problems — some
actions even exacerbate the situation. More data
are not necessarily better. The paper quagmire
generated by data collection can impede any ef-
fort toward improvement and effective manage-
ment. An expanded TRI cannot solve every
environmental issue; however, hysteria about
toxics use and focusing only on specific risks
without considering benefits do not serve the
public good.
Conclusion
Industry wants to be given a tool that, along with
regulations, can be used to improve both opera-
tions and the environment. The TRI is only part of
a set of tools, not the whole picture. Priorities for
exposure and risk must be incorporated with con-
siderations for relative toxicity and the TRI emis-
sions data. A holistic approach based on sound
science, reason, and pragmatism that truly helps
industries improve the quality of life is the only
way to deal with today's environmental concerns.
Recommendations
With four years of reporting behind us, we have
learned from our experience. Some recommenda-
tions for developing a reporting system have be-
come clear.
36
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E.A. FISHER
• A release Inventory should focus on releases.
The Toxics Release Inventory of emissions in-
cludes both releases and transfers to off-site treat-
ment, storage, and disposal facilities. In 1988,
over 25 percent of the pounds reported in the
database were transfers, not releases. The mis-
representation of transfers as equivalent to
releases distorts these data and obscures the
priorities. The combined data make it difficult to
measure progress on priorities set for release and
risk reduction.
• The chemical list must be developed based
upon sound science, with the specific purpose of
the TRI in mind and with care to include truly
toxic chemicals. The list of TRI chemicals, called
the list of toxics, includes nontoxic chemicals and
does not include some that are toxic. It was
created by combining two preexisting chemical
lists that were developed for other purposes.
Some of the chemicals were listed because they
are used in high quantities. No emissions are
reported for almost 20 percent of the chemicals on
the list, and some are not used by manufacturers
in significant quantities.
• The regulated community should include the
major emitters of toxic chemicals. Only manufac-
turers in a given set of Standard Industrial Clas-
sification Codes have been targeted to report
emissions for the TRI. Thus, emissions in the
database are only from a select group of emitters
and do not represent a complete inventory. Care
should be taken, however, not to logjam the sys-
tem by including small emitters of negligible
quantities of chemicals.
• Efforts should focus on collecting useful data
because this information determines goals and
priorities. The TRI database cannot solve every
environmental problem but should be used as a
tool in combination with other tools. Collecting
extraneous pieces of information wastes time and
energy, jams and overwhelms the system, and
detracts from data effectiveness. More data are
not always better. Essential to the process are key
accurate data that can be used and managed to
drive goals and address real problems. Collecting
unnecessary information can obscure relevant
data and push priorities away from risk reduc-
tion.
• A pragmatic, reasonable approach incorporat-
ing sound science and considering relative
toxicities, risk, and exposure should be used to
set priorities. Laws, programs, and goals based
on faulty assumptions or focused on intermediate
waste handling steps will not affect releases to the
environment and exposure to toxic chemicals.
Collecting pertinent data and setting appropriate
priorities is the only way to focus on and improve
the quality of life.
37
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Breakout Sessions
The Breakout Sessions presented the approach used by the U.S. Environmental
Protection Agency (EPA) in implementing a significant right-to-know program
concerning the releases and transfers of toxic chemicals. It is essential to note from the
start that EPA's way of implementing these requirements is being discussed only to
show that the concept can be successfully implemented, not to suggest that EPA's way
is the only approach.
L
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Implementation and Program Issues of
the U.S. Toxics Release Inventory (TRI)
MODERATOR: Mary Ellen Weber
Economics and Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
Sam K. Sasnett
TRI Management Staff
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
Warren R. Muir
Hampshire Research Associates
Alexandria, Virginia
Earl R. Beaver
Waste Elimination
Monsanto Company
St. Louis, Missouri
Robert Costa
ICF, Incorporated
Fairfax, Virginia
Introduction
After two tragic accidents in 1984 and 1985 when
chemicals were released in Bhopal, India, and In-
stitute, West Virginia, the United States enacted
the Emergency Planning and Community Right-
to-Know Act (EPCRA) to improve local
communities' ability to prepare for chemical
emergencies and, more importantly, provide
public access to information on local chemical
hazards. EPCRA establishes a structure at the
state and local levels to assist communities in
planning for chemical emergencies and requires
businesses to provide information on various
chemicals used in their facilities.
One of EPCRA's requirements was a Toxics
Release Inventory (TRI) that would compile in-
dustry reports on annual releases to the air, water,
and land of over 300 chemicals and 20 chemical
categories. The U.S. Environmental Protection
Agency (EPA) was given the task to develop and
implement the TRI. For this program, EPA must
collect and maintain massive amounts of informa-
tion on a database that is publicly accessible
through an on-line computer system and other
means, such as microfiche at local libraries.
To ensure consistent, accurate, and useful
data, EPA carefully designed and coordinated the
TRI program to balance the needs and burdens of
all interested parties — government, industry,
public interest groups, and the public. TRI's key
components include: regulatory development,
outreach, data management, public access, and
enforcement.
41
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Reporting Releases of Toxic Chemicals
Establishing TRI
In establishing the TRI program, EPA had to
determine which facilities would report on which
chemicals. The law mandated the basic reporting
elements and required manufacturing facilities
with 10 or more full-time employees to report an-
nual releases of specified chemicals, including
specific high volume industrial chemicals, car-
cinogens, and water quality priority pollutants.
Because the list of chemicals was compiled from
two prepared earlier by New Jersey and
Maryland, it included some not currently in
production and others that did not meet toxicity
criteria. Therefore, EPA established a petition
process to allow anyone to request addition or
deletion of chemicals based on established
toxicity criteria that include evidence of
• reproductive dysfunction or
• neurological disorders or
• heritable genetic mutations or
• cancerous, teratogenic, and/or other
health effects as well as significant adverse
effects to the environment.
EPA must respond within 180 days to any peti-
tion, and changes to the list must be made under
federal regulatory procedures.
With the list of toxic chemicals as the focal
point, EPCRA mandated that only facilities whose
primary business activities are manufacturing
products for use in commerce are required to
report under the TRI program. Smaller manufac-
turing facilities must have 10 or more full-time
employees and exceed specified reporting
thresholds. The following separate thresholds
were established for particular uses of the toxic
chemicals: manufacturing (including importing),
processing (incorporating) the toxic chemical into
the final product, and any non-incorporative
uses.
To ease the reporting burden, EPCRA re-
quired a phased-in threshold approach.
Thresholds are based on the following culmina-
tive amounts per listed toxic chemical or chemical
category over the calendar year:
• Manufacturing (including importing) or
processing:
• 75,000 pounds (approx. 34,000
kilograms) for calendar year 1987,
• 50,000 pounds (approx. 23,000
kilograms) for calendar year 1988, and
• 25,000 pounds (approx. 11,000
kilograms) for calendar year 1989 and
annually thereafter.
• Non-incorporative uses:
• 10,000 pounds (approx. 4,500 kilograms)
annually.
Reporting TRI Data
While most of the parameters for determining
which facilities should be subject to TRI reporting
were set by statute, the format for reporting infor-
mation was not. EPA had to design a format and
data elements that balanced the need for useful
data with the requirement to provide clear and
concise guidance to the regulated community.
Form R was the result.
Form R is used for two types of information:
facility-specific and toxic chemical-specific. One
Form R must be submitted for each reported toxic
chemical or chemical category. The facility-
specific information requested on the Form R in-
cludes not only physical location but also a
facility identification number that links the TRI
with other databases for different environmental
regulations and for identifying economic ac-
tivities conducted at the facility. Form R also iden-
tifies key personnel who can provide EPA or the
public with further information on a facility's
toxic chemical use.
To meet the toxic chemical-specific informa-
tion requirements, facilities must report the iden-
tity and the use for each toxic chemical used in
processes and indicate how much of each is
released to the environment, transferred off-site
for disposal, or treated on-site. Releases must be
classified by medium (air, water, or land) and by
source: point (discharges to surface water) or non-
point (fugitive emissions from piping). If waste is
transferred off-site, facilities must report the des-
tination and the amount and type of waste treat-
ment, disposal, or recycling.
In 1990, with the passage of the Pollution
Prevention Act (PPA), reporting on waste mini-
mization activities such as source reduction and
recycling, became mandatory. The PPA aims to
minimize waste generation by establishing a
source reduction program at EPA and assisting
states to provide information and technical assis-
tance. Under PPA, facilities are required to es-
timate the total quantity of toxic chemical in
waste that is released, treated, and recycled on-
and off-site and provide a basis for those es-
42
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BREAKOUT SESSION: IMPLEMENTATION AND PROGRAM ISSUES
timates. In addition, facilities must provide infor-
mation on source reduction activities instituted in
each reporting year and include information on
how they identified the activity and what impact
the activity had in reducing wastes.
Facilities are not required to collect new data
but can use available data, such as process infor-
mation, inventory records, data collected through
monitoring required by other laws, and engineer-
ing estimates as the basis of estimates of waste
quantity. No more than two significant digits of
accuracy are required. Facilities must retain
records of this information for three years.
Under EPCRA, only chemical identity can be
claimed a trade secret. Facilities must supply a
generic chemical name on Form R submitted for
public use and substantiation of their trade secret
claim to EPA. In general, only EPA and health offi-
cials have access to trade secret data; however,
concerned citizens can petition for release of a
chemical's identity.
Recognizing that many facilities receive in-
complete information on chemicals contained in
mixtures or trade name products, EPA has re-
quired companies that supply such mixtures or
products to identify the name and concentration
of any listed TRI chemical contained in them. This
information has helped facilities accurately calcu-
late how much, if any, of a listed TRI chemical
they are using. The supplier notification require-
ment does not apply to consumer products, and
certain activities that involve toxic chemicals are
exempt from TRI reporting, including
• procedures that use mixtures containing de
minimis concentrations,
• processes that incorporate toxic chemicals
into articles (acids in batteries),
• laboratory activities,
• janitorial and motor vehicle maintenance,
and
• transportation of toxic chemicals under
active shipping papers.
Assuring Data Quality
To assure the quality of the TRI data, EPA has con-
ducted telephone surveys and site visits to
facilities to identify common errors. Telephone
surveys identify reporting and estimation
problems and provide guidance to improve data
quality. Site visit audit surveys quantitatively as-
sess the accuracy of data submitted from year to
year. Generally, the results are positive: through
increased communications with industry and
clear guidance, data quality has been improving.
As revealed by audit surveys, the main errors
occur during
• threshold determination,
• Form R completion, and
• release estimation.
Each year, EPA tries to reduce errors and in-
crease compliance by focusing expanded out-
reach activities on specific industries where many
errors occur and publicizing enforcement cases.
Ensuring Compliance
To enforce TRI participation, EPA takes action
when either a Form R is not submitted or
evidence indicates a significant data error. Enfor-
cement can be triggered by comparisons of Form
Rs from facilities in the same industry; referrals
on the federal, state, and local level; and com-
plaints. Computer algorithms are used to check
TRI data and generate notices of noncompliance.
The penalty policy promotes consistent actions
and enforcement through EPA inspections as well
as citizen suits to improve compliance, which cur-
rently stands at approximately 75 percent. EPA
has been encouraging facilities to settle cases out
of court through environmentally beneficial ex-
penditures, such as instituting source reduction
activities or providing equipment for local emer-
gency response groups.
Outreach to industry, states, and the public is
another important way EPA ensures compliance.
Examples include training and technical support
for industry, financial and technical assistance for
states, and fee waivers and database assistance
for community groups wanting access to TRI
data.
Conclusion
After more than five years, the TRI program is
still evolving and growing. EPA, Congress, and
other environmental groups are exploring ways
to enhance and expand the TRI program, includ-
ing
• expanding the types of facilities required
to report,
• adding other toxic chemicals to the list.
43
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Reporting Releases of Toxic Chemicals
• requiring reporting based on actual
releases rather than on use thresholds,
• reporting on peak releases as well as total
annual releases,
• mandating data on listed chemicals
entering as well as exiting facilitys'
process(es), and
• requiring facilities to develop toxics use
reduction plans.
EPA has learned many lessons from the years
spent collecting data on toxic chemical releases.
The Agency has determined that centralized
reporting is critical. As technology improves,
magnetic media reporting will help reduce the
data management burden on this centralized sys-
tem. Data quality depends on clear, consistent
guidance and ongoing technical assistance, which
must be periodically improved to reflect the
needs of the respondents. Supplier notification
provides critical data to users of mixtures and
trade name products. Lastly, EPA has found that
aggressive outreach and enforcement can im-
prove compliance and data quality.
44
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Information Management
MODERATOR: Linda Travers
Information Management Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
Steven D. Newburg-Rinn
Public Data Branch
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
Gerald V. Poje
Green Seal
Washington, D.C.
Robert Wevodau
Air Quality Group
Du Pont Company
Newark, Delaware
Introduction
In October 1986, the U.S. Congress passed the
Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA). The Toxic Chemical
Release Inventory (section 313) is one of the major
sections of EPCRA. In defining TRI's purpose,
section 313(h) provides that: "The release forms
required under this section are intended to pro-
vide information to the Federal, State, and local
governments and the public, including citizens of
communities surrounding facilities."
Section 313(j) further states: "The Ad-
ministrator shall establish and maintain in a com-
puter data base a national toxic chemical
inventory . . . [and] shall make these data acces-
sible by computer telecommunications and other
means "
EPCRA requires annual reports to EPA of the
direct release of toxic chemicals to all environ-
mental media (air, water, and land) or off-site
transfer to sewage treatment plants (POTWs) or
other off-site facilities, such as commercial
landfills. All manufacturing facilities — from
orange juice manufactures to car companies to
members of the chemical industry — that have 10
or more full-time employees and manufacture or
process more than 25,000 pounds or use more
than 10,000 pounds of any one of approximately
300 chemicals and 20 chemical categories must
submit these data, which form the Toxic Chemical
Release Inventory (TRI).
When EPCRA was passed in 1986, EPA was
faced with the task of developing a structure to
handle Congress' requirements. Because this was
a totally new endeavor, EPA worked closely with
state and local governments, industry, environ-
mental groups, information providers, and
universities to develop and implement the infor-
mation management aspects of TRI. In retrospect,
it is clear that involving all of the parties with an
interest in TRI early in its implementation has had
a great deal to do with its success.
EPA's TRI Information Management In-
frastructure involves collection, management,
45
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Reporting Releases of Toxic Chemicals
distribution, and integration of the toxic chemical
information. Procedures for each stage are out-
lined in the following paragraphs.
Collecting TRI Information
Before a single document was submitted to EPA,
various tasks relating to the ultimate collection of
data were undertaken. EPA developed guidance
documents, held industry workshops, and estab-
lished a place for industry to call for help. Staff
were hired and a reporting center was established
to handle the influx of data — an average of
85,000 forms per year from 23,000 industrial
facilities.
Each year, facilities receive a reporting pack-
age that contains the TRI forms, an instruction
manual for filling in the form, and a magnetic
media package that enables them to file informa-
tion electronically. Training is offered throughout
the year at industry conferences and workshops
to help avoid any mistakes in completing the
forms. A TRI Hotline is also available to answer
any questions a company may have about the
form or the process (1-800-535-0202; 703-920-
9877).
Managing TRI Information
To manage TRI information, systems were
developed to keep track of all documents and
store and aggregate data, allowing analysis. A
comprehensive data quality program has been es-
tablished, which includes quality management of
data processing, industry review of release num-
bers, and release estimate assessments, including
on-site evaluations.
The magnitude of the TRI data collection is il-
lustrated by the following figures for number of
individual chemical forms, by year, as of Novem-
ber 1991:
• 1987: 79,057;
• 1988: 84,693; and
• 1989: 82,513.
Facilities submit an average of 60 data ele-
ments per form for each reporting year. EPA
entered over five million data elements from
forms received for 1987 through 1990. In the fall
of 1990, Congress passed the Pollution Prevention
Act of 1990, effective for the 1991 reporting year
and thereafter. The act added about 50 percent
more data to TRI reporting and will lead to be-
tween eight and nine million data elements for
1991 reporting. Other activities underway that
either increase the number of facilities required to
report or the number of chemicals on which
reporting will be required will affect this total.
Three procedures ensure data quality. The
first identifies and corrects data entry errors.
Next, errors in facilities' data are identified and,
where possible, corrected. The final procedure en-
hances data submitted by facilities.
During data entry, computerized edits and al-
gorithm checks are used to verify the keyed infor-
mation. Edit checks, which occur at the point of
data entry, prompt the keyers to verify a variety
of critical fields, including:
• Facility name,
• State/city/zip code,
• Latitude/longitude,
• Possible duplicate submissions,
• Presence of negative values, and
• All release data over 100,000 pounds.
In addition, computerized algorithm checks
are made on:
• chemical name/CAS number,
• facility Dun & Bradstreet number,
• parent company Dun & Bradstreet
number, and
• NPDES permit numbers.
Four separate activities ensure a high level of
data entry reliability. First, at least 25 percent of
each keyer's work is verified. Following this step,
random audits of data entry data quality are
taken. (The accuracy rate at this stage is about
99.5 percent. After the next three steps, this rate is
even higher.) Next, a variety of reports are used to
identify aberrations, then each facility is mailed
its release and transfer numbers to verify. Finally,
high-level staff manually examine critical data
elements after all data for a particular year have
been entered.
Most numbers reported are relatively small;
however, to study trends, scientists must be con-
cerned with the many large numbers for releases
and transfers found in the database, and the final
checks before data release recognize this. All
numbers over 500,000 pounds are verified. In ad-
dition, EPA verifies all release/transfer numbers
that cause a facility to be selected as one of the top
25 in a state by total releases and transfers or one
of the top 25 facilities in a state .by environmental
media. Additionally, the top 250 facilities by
46
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BREAKOUT SESSION: INFORMATION MANAGEMENT
amount of increase and the top 250 by amount of
decrease are also verified. In addition, reports are
sent to the regions and states for another look
before public release.
In addition to these data quality procedures
for EPA staff, a number of activities are under-
taken to determine whether submitters have done
their jobs correctly. Notices of Noncompliance are
issued when the facility has made such a sig-
nificant error that the data cannot be entered.
Notices of Technical Error are issued when a com-
puterized check of the submitter's data (verified
by a person) indicates a problem in submission.
Additionally, computer-generated changes are
used to clean up table values and county names,
verify zip codes, states, and counties, and where
possible, correct submitted latitude and longitude
numbers.
Because computers do not really "think," it is
often necessary to normalize data categories to
enhance usability. Some significant normalization
has occurred with respect to county names,
facility names, parent company names, inserting
zip code centroid latitude and longitude, and in-
serting Federal Information Procedure System
codes for state and county.
Distributing TRI Information
The wide range of users of TRI data has indicated
a need for multiple products, training, and ser-
vices. EPA makes TRI data available through
"computer telecommunications and other
means." The states and others (such as industry,
environmentalists, the media, and health officials)
also make these data available in various unique
ways.
TRI information is distributed to a variety of
users, including EPA employees in both Head-
quarters and the regions, local and state govern-
ment employees, academics, librarians, health
professionals, industry, and private citizens. Na-
tional, state, and local governments are using the
data to shape both voluntary and regulatory en-
vironmental programs, and many companies are
deciding to make dramatic voluntary reductions
in toxic releases. Private citizens are studying
data on releases of chemicals in their com-
munities. This information has created a strong
demand for further analysis and facilitated com-
parison across the different environmental media.
These multiple users have varied needs, such
as national or state data sets, extracts, and
analyses, so information is distributed through
different means. For example, while developing
the original infrastructure, a partnership was
formed between EPA and the U.S. National
Library of Medicine, which added the Toxics
Release Inventory to its previously established
health and environmental information network.
This online means of assessing TRI data has al-
ready answered over 300,000 database queries.
In addition to online service, EPA provides
TRI data in other formats, including a national
report that is an easy-to-understand summary of
the database and microfiche located at over 3,300
U.S. libraries. Diskettes of each state's emission
reports have been distributed to 50 state health
and environment departments, and more than
500 libraries at universities across the United
States have the database on CD-ROM. Magnetic
tape is also available for those interested in ad-
ding the TRI information to their large computer
system. All of these products are available at
reasonable prices to anyone who wants them.
In addition, training sessions are held
regularly for both industry and the user com-
munity. A TRI Hotline and a user support service
line (TRI US) have been established to help less
sophisticated users in programs and searches.
Integrating TRI Information
TRI continues to expand with each additional
year of data added to the system. As the system
grows and more users become familiar with the
data, the number of uses and opportunities for in-
tegrating TRI with other databases will continue
to expand. As of 1991, three years of data are
available, which allows for multi-year trend
analyses. Because of the geographic orientation of
TRI, data can be displayed through the
Geographic Information System.
TRI has been a driving force for linkage to
other information sources. The use of common
data elements (for example, facility name) allows
matching with other databases to create new in-
formation sets. As the only publicly available
database for multi-media environmental informa-
tion, TRI and its uses will continue to grow.
47
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Computer Tools for TRI Analysis
MODERATOR.- Loren Hall
Risk Guidance Development Staff
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
Robert Palmer
General Sciences Corporation
Laurel, Maryland
Gary Hamilton
ViGYAN, Inc.
Falls Church, Virginia
Risk Assessment and Risk-based
Decisionmaking
Toxics Release Inventory (TRI) data can support
many risk-based decisions, including ones that
establish priorities for follow-up risk evaluations
and target subcategories of facilities, chemicals,
industries, and geographic areas for voluntary
reduction efforts, enforcement, or regulatory
development. Such decisions must focus on rela-
tive rather than absolute and quantitative risks.
Despite uncertainties in release estimation
methods, range reporting, and limited coverage,
TRI data are still extraordinarily useful for rela-
tive risk evaluations. This information can also
provide a starting point for absolute risk evalua-
tions that may be needed to support development
of regulations.
Major features of risk assessment are usually
incorporated in these analyses either explicitly or
implicitly. The risk assessment process includes
consideration of a chemical's toxicity to various
organisms, release patterns and characteristics,
and environmental transport and fate as well as
the presence, size, and types of exposed popula-
tions.
Although several common types of TRI
analyses (summaries of total releases and trans-
fers, for example) do not appear to be risk-based,
they can be considered so by using the following
simplifying assumptions:
• The toxicities of all chemicals are the same,
• The potential for exposure is the same for
each release medium,
• No differences exist in environmental con-
ditions from facility to facility, and
• The size of the potentially exposed popula-
tion is assumed to be equal or not regarded
as significant.
Assessment Tools for Risk
Decisions
Major TRI assessment tools that support risk
screening applications include software for
database management, graphic display and map-
ping, and statistical analysis; the Geographic In-
formation System (GIS); and exposure and risk
models. All can be used at several decision levels.
49
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Reporting Releases of Toxic Chemicals
Such factors as available data and personnel,
time, cost, and the degree of uncertainty accept-
able in a particular decision influence the choice
of tools. Typical TRI analyses performed on com-
puters include simple combinations of releases
and transfers, toxicity-weighted combinations,
and use of TRI data with environmental models
for semi-quantitative or quantitative risk es-
timates.
Simple Assessments
Simple combinations usually include summations
of release data or releases and transfers. Most
summaries can be compiled through database
management systems by facility (across chemicals
and release media), geographic area (county), in-
dustry sector, chemical, or medium. To support
such analyses, EPA uses dBase, AD ABASE, SAS,
and the ARC/INFO CIS. The Office of Pollution
Prevention and Toxics has developed a set of SAS
routines, collectively called TRIPQUIC, that allow
easy construction of summaries, which can be dis-
played as tables, graphs, or maps. These simple
combinations are constructed directly from
verified data contained in TRI submissions.
Weighted Combinations of
Emissions
Weighted combinations of release data most often
use information on toxicity endpoints of TRI
chemicals to weight the releases and transfers.
Such weights can be constructed on the basis of a
toxicity ranking, either qualitative (high-medium-
low) or quantitative (for example, 6 on a scale of 1
to 10). Weights can also be derived directly from
toxicity values: LDso, cancer potency slope fac-
tors, or acceptable dose levels.
Producing weighted combinations of release
data is a relatively straightforward process when
databases of toxicity information can be related to
release data files by a Chemical Abstracts Service
number. Reports can be created by choosing only
selected carcinogens or by multiplying releases by
a toxicity rank or concern level. TRI data have
been used by analysts in several EPA regions,
states, and interest groups to develop such
weighted assessments. In most cases, though,
these combinations do not include an exposure-
based weighting scheme.
Qualitative Risk Screening
Using risk screening to develop relative in-
dicators of concern incorporates additional ex-
posure information and allows greater use of
professional judgment in determining priorities.
EPA's TRI Risk Screening Guide provides one sug-
gested approach. Developed to support reviews
of TRI data by local officials (especially those not
already involved in conducting risk assessments),
the guide suggests consideration of releases,
toxicities (human and aquatic), environmental
fate, receptor populations, and uncertainties or
gaps in release and toxicity data. The primary
output of a risk screening assessment (as
described in the guide) is a grouping of facility-
and chemical-specific releases into high-medium-
low categories.
Risk screening assessment is most ap-
propriate for small area comparisons, such as 10
to 50 facilities in a county, because of the time in-
volved in manipulating the appropriate data. EPA
is developing an automated version of the guide
to support analyses of larger groups of releases,
and various TRI data users are considering
numerous other approaches to risk screening.
The process of risk screening requires data on
chemical releases, toxicity information, chemical
fate parameters, and distribution of human as
well as wildlife populations and environmentally
sensitive areas. A wide range of health and en-
vironmental effects were considered when the
guide was developed, including chronic toxicity,
carcinogenicity, human acute toxicity, and acute
and chronic toxicity to aquatic organisms.
Toxicity ranking factors can be developed
from existing regulatory levels, such as the Com-
prehensive Environmental Response, Compensa-
tion, and Liability Act's reportable quantities, or
from data on effective dose levels, called "refer-
ence doses." Major toxicity data sources for risk
screening include the TRI Risk Screening Guide's
Appendix A, Roadmaps' PC database, the In-
tegrated Risk Information System, other on-line
data sources such as the Hazardous Substances
Data Bank, the International Agency for Research
on Cancer's chemical monographs, and the Inter-
national Register of Potentially Toxic Chemicals'
toxicity data.
Major site-specific data used in risk screening
include:
• wind speed and direction,
• stream flows,
50
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BREAKOUT SESSION: COMPUTER TOOLS FOR TRI ANALYSIS
• soil characteristics, and
• receptor population information.
Data are often available from local weather sta-
tions, natural resource management agencies, and
planning or health organizations. Information to
support evaluations of receptor population can be
derived from maps showing household distribu-
tion or from a census of population retrieved by
using PC GEMS or GIS, which can also delineate
sensitive populations (schools and hospitals) and
environments (wetlands and parks).
The Office of Pollution Prevention and Toxics'
Graphical Exposure Modeling System (GEMS) in-
cludes many features for risk screening applica-
tions. PC GEMS supports data management and
retrieval, mapping of points or areas, and multi-
media exposure modeling. However, the most fre-
quently used TRI risk evaluations cannot support
the amount of data required for a quantitative
modeling assessment. PC GEMS also requires
considerable hard disk space on a personal com-
puter, and therefore, a subset, Screen GEMS, has
been developed to support risk screening. The
features of Screen GEMS include:
• Data on selected environmental charac-
teristics, such as prevailing wind patterns
and stream flows;
• Receptor information, including data to
construct tables of populations living near
sites and identify downstream drinking
water intakes; and
• Integration tools that assist in developing
site maps of population, rivers, and politi-
cal boundaries.
Quantitative Risk Screening of TRI
with Environmental Models
In risk-based decisions, TRI data often can be en-
riched by incorporating computerized models in
the evaluation. Key issues in such assessments are
the availability of additional input data and the
degree of uncertainty that can be communicated
readily to users. Models provide a convenient
way to incorporate site-specific factors affecting
exposure and may allow calculation of risk es-
timates on relative toxicity. However, the TRI
reporting form does not include all the data
necessary for a modeling analysis. If the decision
to be supported allows their use, generic release
input parameters may be appropriate. In other
cases, additional site-specific data may be needed
to support more accurate risk assessments.
TRI data can be evaluated by using semi-
quantitative modeling with generic input data or
quantitative risk modeling with site-specific in-
formation. The semi-quantitative approach
employs the models' numerical results in a
qualitative sense to support scoping or ranking.
In such cases, the facilities or chemicals with the
highest estimated risks can be grouped as a
priority for additional action. A fully quantitative
approach allows estimation of population risks to
determine permit limits or other regulations.
The major differences between the two ap-
proaches are the data requirements, necessary ex-
pertise, and uncertainty of results. For example,
significant additional data are needed to conduct
an atmospheric exposure and risk assessment
using a model in GEMS or PC GEMS. The In-
dustrial Source Complex—Long-term model es-
timates annual average concentrations from stack,
area (fugitive), or volume emissions. Major inputs
to estimate data include site location, emission
rate, and stack data (height, temperature, velocity,
diameter), together with wind speed and direc-
tion. To additionally estimate exposure, data are
required on population distribution around the
site. Also, annual average concentrations and ex-
posure can be used in conjunction with a cancer
potency unit risk factor to estimate individual
and aggregate cancer risks over a lifetime. The
TRI form provides only the annual total emis-
sions of each chemical (from all sources within a
facility) and site location.
The Office of Pollution Prevention and Toxics
employs semi-quantitative risk screening in the
Existing Chemicals Process to target chemicals for
possible regulation under the Toxic Substances
Control Act and highlight possible facilities for
voluntary emissions reduction of TRI chemicals.
Such assessments are being developed for about
30 TRI chemicals, with all TRI sources in the
United States modeled for each.
EPA has not attempted to develop reliable
quantitative risk estimates for TRI chemicals
using site-specific data. Such an effort would re-
quire contacting facilities for detailed data on
most or all of the individual stacks or vents and
better estimates of size and perimeter boundaries.
TRI data reported by industry are summarized
not only from many production processes but
also from multiple release points within a process.
In a fully quantitative assessment, such sources
should be evaluated individually.
A major new analysis tool recently available
within EPA and elsewhere, therGeOgrapruc Irifor-
51
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Reporting Releases of Toxic Chemicals
mation System (GIS), can support a variety of TRI
analyses. GIS manages both geographic and
geographically referenced "attribute" data; in
TRI, these data are single points that represent
facilities. Examples of geographically linked at-
tribute data used in TRI risk screening include
TRI releases and transfers, populations associated
with census enumeration areas, stream flows
linked to stream segments, and populations as-
sociated with drinking water utilities.
The GIS includes a standard database
management system that can manipulate at-
tribute data, and its ability to develop informa-
tion about spatial relationships not assessed
before is especially powerful. A simple example
of a spatial analysis would be a total of all records
within a single county, when the county name or
code is part of the record. Such analyses can be
supported in most database environments and in
SAS.
An intermediate example of spatial analysis
might be a summation of all points within a
specified distance and direction of another point
— such as populations or postal zip polygon
centroids near a facility. An advanced example of
GIS assessment might be a computation of total
acreage of endangered species habitat within a
floodplain downstream of a TRI facility, given the
facility location, river trace, topography, and rain-
fall and species ranges. The GIS can also support
development of models or scoring systems.
EPA regions are using GIS to integrate data
collected to implement environmental laws and
support risk-based priority setting. At least two
regions have developed TRI scoring systems that
assign weights to releases and transfers by degree
of chemical toxicity concern.
Conclusions
The TRI is extremely useful for risk-based
decisionmaking. Most applications involve some
form of simplified risk assessment or screening to
target application of scarce resources on releases
presenting the highest risks.
Many decisions can be supported by TRI
analyses; however, they may require assessments
with different levels of specificity and accuracy.
Because of uncertainties in emissions data and
cost and time requirements to collect additional
information, most decisions that rely on TRI
analyses depend on relative risk between one
group of chemicals, facilities, industry sectors,
and geographic areas and another. Often, a high-
medium-low ranking can be used.
Data needs for assessments vary according to
which elements of risk are considered and the de-
gree of uncertainty that is appropriate to a
decision. Chemical toxicity data are needed for
risk screening. Several kinds of site-specific data
on environmental conditions and receptor
populations are required to extend evaluations to
include exposure factors.
EPA's TRI Risk Screening Guide outlines a
process that results in high-medium-low rankings
of facility-chemical combinations. Its appendices
contain useful information on relative chemical
toxicity and environmental fate parameters.
Numerous computer tools can provide access
to data needed for risk screening and support
various analyses. Notable examples include
database management systems (ADABASE,
dBase); statistical packages (SAS); the Geographic
Information System (ARC/INFO and mapping
packages); and environmental models (GEMS
and PC GEMS).
Models make incorporation of most factors
needed for risk-based assessment relatively easy.
However, the results of modeling analyses, par-
ticularly those created with generic input as-
sumptions, should be used cautiously. Such
results can often be used qualitatively to help set
relative priorities. Several EPA offices have found
these approaches useful in performing TRI data
analyses. Many other TRI data users are exploring
the use of these and related techniques in their
analyses.
52
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Data Use and Analysis
-------
Environmental Priorities with the
Toxics Release Inventory
Mary Ellen Weber
Economics and Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
ABSTRACT
The Toxics Release Inventory (TRI) data are used at the U.S. Environmental Protection Agency to
target resources and help establish priorities. This session will explore various initiatives in
which EPA and private industry enter into cooperative joint ventures to prevent pollution using
TRI data as the measure of success. It will also discuss regulatory activities at EPA that have
been triggered by an analysis of the TRI data and its influence on laws passed by the United
States Congress as well as by local governments in the United States. An analysis of TRI's role in
focusing environmental inspection and enforcement activities will complement the description
of its role in pollution prevention.
The Toxics Release Inventory is used by dif-
ferent people for different reasons. It is
certainly used by the states and federal
government, but also by the press, academic and
citizens' groups, and industry. My presentation
will focus on how EPA and Congress rely on TRI
when developing legislation and regulations. EPA
also uses TRI to enforce the regulations, assess en-
vironmental and health risks, and measure our
environmental progress.
During this past year, a number of important
federal activities were heavily influenced by TRI,
including several pieces of legislation. The most
important for the Toxics Release Inventory and
the Office of Pollution Prevention and Toxics has
been the passage of the Pollution Prevention Act
of 1990, which puts into law EPA's policy to
prevent pollution from being generated in the
first place. This act establishes a source reduction
program at EPA and provides state governments
with technical support, particularly for smaller
businesses, in determining pollution prevention
opportunities.
The Pollution Prevention Act charged EPA to
establish a pollution prevention office, now the
Office of Pollution Prevention and Toxics. EPA
has developed a strategy, set up grants for state
and local governments, and established a source
reduction clearinghouse that exchanges publicly
available information on pollution prevention
techniques, processes, and process changes. EPA
also gathers information on source reduction,
recycling, and changes in releases under the TRI
reporting requirements.
We call the report collected under the TRI the
"Form R" for releases. Basically, Form R tells com-
panies to look aggressively and actively for pollu-
tion prevention opportunities, document what
kinds of action they have taken to determine
those opportunities, and, most importantly, to
predict what they are going to do in the future.
The other uses of TRI at EPA are interesting.
We perform a fair amount of targeting of our en-
forcement and inspection activities, using the
toxics release information. Because these are
multimedia data, we are able to compare the
55
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Reporting Releases of Toxic Chemicals
reports for air and land emissions and, for the
first time at EPA, to actually put together teams
that will go out and do multimedia enforcement.
Also, we can look at priority enforcement targets
based on the amounts of emissions that have been
reported because they are very high or do not
look very logical and suggest that something may
be wrong with the kind of report being used. TRI
allows us to leverage our enforcement resources,
to use them where they will do the most good.
In addition, we have been encouraging en-
vironmentally beneficial expenditures. EPA can
fine a company for failing to follow regulations;
however, if the firm can demonstrate that it has
voluntarily engaged in substantial expenditures
for pollution prevention, it will get a partial credit
against the fine. This is one of the ways TRI has
advanced EPA thinking on enforcement.
TRI has been used by other agencies to
validate other laws. The Internal Revenue Service,
the United States' tax collection agency, has com-
pared emissions reports with the amount of taxes
collected, thereby using TRI as an enforcement
tool. State and local governments, particularly
local municipalities, have also used TRI data to
assess the appropriateness of different kinds of
buildings in a particular neighborhood. For ex-
ample, should a school be permitted to be in an
area where emissions or releases have been
reported? Banks have also used the data to deter-
mine the riskiness of financing the purchase of
particular pieces of real estate.
EPA has been using TRI information to more
narrowly focus risk assessments. The list of
chemicals included under the TRI was given to
EPA by Congress. EPA is evaluating this list sys-
tematically for potential new additions. Of the 77
TRI chemicals that have been subjected to priority
screening so far, EPA's Office of Pollution Preven-
tion and Toxics has identified 57 chemicals for
more detailed testing that will undoubtedly in-
fluence regulations.
TRI is also being used by other EPA offices to
assess risk and regulate activities. For example,
the Office of Water has used the TRI to identify
possible sources of well and groundwater con-
tamination. TRI data are also used to identify
sources of toxic discharges into nationally sig-
nificant estuaries near our Great Lakes as well as
in the Gulf of Mexico area, where EPA has major
priorities. The TRI also helps to identify priority
geographic areas of the country where EPA could
concentrate efforts and resources.
The TRI also measures progress. To determine
whether people really are reducing pollutants,
EPA is studying pollution prevention practices,
including kinds of activities, to create a TRI en-
vironmental indicator program.
One of the most publicly acclaimed programs
at EPA is the 33/50 Project whose goal is to have
selected corporations voluntarily reduce 17
selected TRI chemicals 33 percent by 1992 and 50
percent by 1995. Six thousand major U.S. corpora-
tions were asked to sign up for this program; to
date, 700 have voluntarily promised to meet or
exceed these goals for the 17 chemicals. A number
of companies have voluntarily committed to meet
the same goals in their international operations.
The 1988 TRI data will be the baseline for measur-
ing progress in the 33/50 program.
The new Pollution Prevention Act requires
companies to identify the methods used to find
pollution prevention opportunities and then
report which process actually reduced pollution.
An EPA clearinghouse will contain that data as
well as the Form R reports, and they will be
publicly available.
It has been difficult to determine, however,
whether the environment is really better off. Now
that EPA has three years of data, it can start as-
sessing trends.
Other issues include changes companies
make in methods of accounting and measure-
ments to understand better how the law applies
to them. Unfortunately, EPA does not have an
easy way to determine the relative risk associated
with the chemicals in the TRI because it cannot
measure what an increase or decrease of 10 mil-
lion pounds means for the environment as a
whole.
EPA is now trying to develop a Toxics Release
Inventory indicator that will determine whether
the United States is better off and whether it is
making environmental progress. This indicator,
which is not a measure, is highly controversial be-
cause it will require some balancing of a number
of scientific, policy, and philosophical judgments;
i.e., things like carcinogenicity and reproductive
and environmental hazards. But we are con-
vinced that we need to go farther than simply an-
nouncing total pounds or total kilograms each
year.
The TRI indicator is a priority of EPA Ad-
ministrator William Reilly. EPA will use it to allo-
cate resources so that they are sent to areas where
risks can be reduced most efficiently and effec-
tively.
56
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Air Quality and the TRI
Denise Devoe
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Washington, D.C.
ABSTRACT
The Office of Air Quality Planning and Standards, charged with implementing most stationary
source regulations under the Clean Air Act, has used the Toxics Release Inventory for many pur-
poses, most recently as a focal point for the debate over'development of the list of 189 chemicals
called for by the newly amended Clean Air Act. The staff have also employed the TRI to identify
industry sectors that need additional regulation and guidance and to choose corporations to
work with to voluntarily reduce emission levels. In the future, the staff will use these data to fur-
ther develop office priorities.
Introduction
Chemical toxics. They can be found in improperly
treated sewage wastewater, in stormwater runoff
from farms and fertilized lawns, in emissions
from chemical plants, and in automobile ex-
hausts. No matter where it comes from, however,
toxic pollution is a potentially deadly problem.
The U.S. Environmental Protection Agency (EPA)
has always worked aggressively toward eliminat-
ing toxics in the United States; the Office of Toxics
Substances' accomplishments with the Toxics
Release Inventory (TRI) affirms the importance of
our activities.
Once, toxic problems were believed to be con-
fined to industrial areas, but current research
proves that the threat of contamination is much
more pervasive. The TRI has presented oppor-
tunities within EPA by providing a powerful tool;
the Office of Air and Radiation has turned those
opportunities into action. We've used the data to
build a clear picture of the toxics of most concern
in our nation and pinpoint the sources of those
toxics.
Picture a jigsaw puzzle that depicts the total
of all the air toxics emissions in the United States.
Some of the pieces are large and easy to pick out,
such as a chemical manufacturing facility; others,
such as the misapplication of pesticides by a
farmer, are small and harder to locate. It takes all
the pieces to complete the puzzle, but the only
way to do that is one piece at a time. The Toxics
Release Inventory, which provides us with infor-
mation on 300 individual chemicals in 20 chemi-
cal categories, adds many pieces to our air toxics
puzzle.
In the United States in recent years, the im-
portance of air toxics control has grown immense-
ly in the eyes of the public. One reason is the
accidental release of air toxics in Bhopal, India;
another is the publication of the TRI data, which
has attracted attention from government officials,
industry, environmentalists, and the media. That
attention has given EPA's air quality staff momen-
tum and enabled use of the TRI information to
target reductions in air emissions of hazardous air
pollutants.
57
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Reporting Releases of Toxic Chemicals
Sources of Air Toxics in the
United States
Sources of air toxics can be broken down into
three categories: industrial point sources, area
sources, and accidental releases. The latter are
potentially the most serious, as we saw in Bhopal,
India, but as the word "accident" suggests, do not
lend themselves to the use of a database for
regulatory purposes. Area sources, such as the
misapplication of pesticides or the release of
chemicals by a dry cleaning operation, are the
sum total of many small sources that singly may
not present a high risk but coupled together,
present an unacceptable risk.
Those nonpoint sources are important, but
they are not usually as great a risk as the multi-
tude of identifiable point sources in the United
States. A point source is a single source of air pol-
lution that is definable. An example would be a
manufacturing plant. The TRI has identified 1.7
billion pounds of toxic chemicals that were
released to the air from point sources in 1989.
The Role of the TRI in Developing
the Clean Air Act
Air emissions comprise about 42 percent of the
total releases and transfers tracked by TRI from
1987 to 1989 (Fig. 1) — twice as much as any other
category in the entire database and almost half of
the whole total. By gathering that information,
coupled with estimates of the risk involved, the
United States has two more pieces of the puzzle
and can establish priorities.
The TRI database helps us plan and delineate
where we as a nation will place our resources and
efforts and allows us to track our progress. In ef-
fect, it helps us keep track of the size of the puz-
zle.
The TRI data also provide us with much
needed information on which toxic air pollutants
each industry is contributing to the problem and
how much each year. Figure 2 shows the various
industries and the amount of air toxic emissions
produced by each. EPA's Air Quality Office is
developing better control techniques guidance for
some of the industries, such as printing and the
wood furniture coatings, and has assembled
workgroups (called "clusters") to address them
from a cross-media perspective.
The petroleum industry is one such cluster
where Air Quality and other Agency offices are
combining data and resources to reduce emis-
sions to air, land, and water. Another industry
being examined from a joint perspective is the
pulp and paper manufacturers. TRI is one of the
tools the Agency staff use to develop the complete
picture of where the industry is located, how
much pollution results, and how best it can be be
controlled or prevented. Furthermore, EPA can
take a look at specific chemicals being emitted in
large quantities, information that helps determine
priorities.
Currently, Air Quality is looking at
hydrochloric acid, chloroform, ethylbenzene,
acetaldehyde, and other chemicals as a result of
the amended Clean Air Act (Fig. 3). The TRI was
one source of information used by congressional
staff to develop a list of 189 toxic chemicals that
was included in the revised air toxics provisions.
10% Transfers to
Public Sewage
21% Underground
Injection
8% Total On-sHe
Land Disposal
3% Surface Water
Discharges
Source = TRI Report
16% Off-site Transfers
42% Total Air
Emissions
1989 Total:
5.7 Billion Pounds
Figure 1.—TRI chemicals: environmental distribution
of releases and transfers, 1987-89.
CEO Voluntary Reductions
In March 1989, EPA published the first TRI
reports. By providing the information in a format
easily understood by the American public, the
Agency created a powerful tool. We put a piece of
the air toxics puzzle into the hands of everyone
who was interested, and some Americans began
using the data to assess air toxic problems in their
community.
Zeroing in on cleaner air in 1989, Con-
gressman Henry A. Waxman used the informa-
tion to create public interest in air toxics issues.
Representing California, one of our states with
the most serious air pollution problems, Waxman
58
-------
D.CEVOE
Industry (SIC Code)
No codes 20-39
Multiple codes 20-39
Miscellaneous
MeasureJPhoto.
Transportation
Electrical
Machinery
Fabr. Metals
Primary Metals
Stone/Clay
Leather
Plastics
Petroleum
Chemicals
Printing
Paper
Furniture
Lumber
Apparel
Textiles
Tobacco
Food
I I Off-Site
C~3 Public
Sewage
Underground
Land
Surface
Water
Air
i
20
40 60
Percent
80
100
Figure 2.—The environmental distribution of TRI releases and transfers of each Industry, 1989.
Source = TRI Report
Figure 3.—Increases In emissions to air greater than
one million pounds, 1988-89.
was later instrumental in amending the Clean Air
Act.
As a result of the attention Congressman
Waxman drew to the amount of air toxics
produced by various industries, EPA Ad-
ministrator William Reilly initiated a project for
the Office of Air Quality Planning and Standards:
to persuade the chairmen of 25 prominent United
States corporations to participate in a voluntary,
cooperative effort to reduce their industry's toxic
emissions. The group was then narrowed to nine
chief executive officers (CEOs) representing 40 of
the 205 facilities whose emissions were believed
to produce the highest cancer risks. Air Quality
worked with these CEOs to identify ways in
which their emissions could be lessened, and, in
September 1990, they committed to reduce their
companies' air emissions.
These commitments did not stem from
regulation but are the direct result of public atten-
tion and creative cooperation between EPA and
industry. They illustrate how the collection and
use of data can facilitate toxic reductions. Two
months later, in November 1990, the United States
Congress amended the Clean Air Act.
The Clean Air Act
The chart in Figure 4 outlines the major com-
ponents of the air toxics provisions of the
amendments' air toxics provisions. Under the
1977 Clean Air Act amendments, EPA regulated
air toxics by establishing a level of acceptable
risks for toxic or hazardous air pollutants. This
was a very difficult task, and all too frequently it
ended in dispute and litigation. In the new
provisions, hazardous air pollutants will be regu-
lated by placing them into categories or groups
and then determining the control technology or
59
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Reporting Releases of Toxic Chemicals
Pollutant
List
Petitions
11 month review
1
Review | —
Within a years
Source
List
1 , Hani
Regulatory
Agenda
Published in
lyear
ting
Published in
2 years
12 month nulen
Within 8 years
Three Year
Compliance
Compliance
Extensions
90%/95%
Emission
Reduction
6 yr. extension
Installation
of Controls
1 year extension
*
*>S.
BACTor
LAER
Syts-from
insUHation
*
Figure 4.—Clean Air Act amendments: air toxics
provisions.
technique that can maximally reduce the toxic air
emissions.
In Figure 4, the three highlighted boxes indi-
cate where the TRI plays an important role in our
regulatory process. This is also true for media
other than air, including solid waste and water.
The first box is the pollutant list. By examin-
ing TRI data on emissions from United States in-
dustries and evaluating scientific data on toxicity
of certain pollutants, EPA will establish a list of
toxic chemicals or pollutants to use as a basis for
regulating air toxics. As a result, the Agency may
modify the list of 189 chemicals established by
Congress for the Qean Air Act.
The second box — source category list — rep-
resents the requirement that EPA list all categories
and subcategories of sources of chemicals on the
pollutant list. By using the TRI, Air Quality can
identify some of these sources.
The third box — regulatory agenda — repre-
sents the Clean Air Act requirement that EPA
determine the priority or order in which regula-
tions are created for these categories. Again, these
decisions can't be made in a vacuum; all available
tools, including TRI, are needed to create this
order. By using the data (the pieces of the puzzle),
we can decide how and when the puzzle picture
should be changed. As a large industrial nation,
the United States cannot set new regulations for
all its industries simultaneously. Priorities must
be established.
The emission reduction box in Figure 5 refers
to the Early Reductions Program. As part of the
newly amended Clean Air Act Air Toxics
provisions, companies may apply for a com-
pliance extension by participating.
Early Reductions Program Under
the Newly Amended Clean Air Act
During 1991, the Office of Toxic Substances has
been working very hard to set up the 33/50 or In-
dustrial Toxics Project, a voluntary program that
encourages companies to reduce emissions to all
media, including air.
In the Clean Air Act Early Reductions Pro-
gram (Fig. 5), commitments made by companies
are legally enforceable because the act excuses
them from complying with the new air toxic
standards for six years. Both programs expect to
achieve significant reductions over the next four
years. To comply with extensions, companies
must reduce their emissions 90 percent (95 per-
cent for particulates) from a baseline mutually
agreed upon with EPA. The information on pre-
vious emissions reported to the TRI and other
EPA databases will be used to establish that
baseline and to monitor reductions. Note that
trading between chemicals is allowed. Both the
33/50 and Air Toxics programs expect to achieve
significant reductions through maximum achiev-
able control technology (MACT) over the next
four years (Fig. 6).
Early in 1991, Water Quality used the TRI
database to select the names of 1,000 candidate
companies for the Early Reductions Program. Al-
though the program will not be final until
January 1992, Air Quality has already begun to
work with companies to identify how they can
take part in it. Committed to participate are: Al-
lied Chemical, Du Pont, Merck, 3M, and Monsan-
to, with many other companies expressing
interest. Air Quality is planning to promulgate an
air toxics standard for chemical plants and ex-
pects a heavy concentration of submittals from
chemical plants in early 1992.
The Chesapeake Bay Program
Both the Early Reductions and the 33/50
programs will play a role in restoring and
preserving the Chesapeake Bay, one of the United
60
-------
D. DEVOE
Plant Emissions (%)
Incentive for industry to
reduce toxic emissions
early
— Allows 6 year extension
of deadlines
— Industry must reduce
toxic emissions by 90%
(95% for participates)
— Provides flexible trading
program between
chemicals
Figure 5.—Air Toxics Early Reductions Program.
The Air Toxics Program: The First MACT
Standards and Early Reductions
Propose first group
of MACT standards
Promulgate
early reduction
guidance
* 1
1991
|
•M
1992
Industrial Toxics
Project announced
Promulgate first group L«
of MACT standards d<
«
itest compliance
;adline for
rst MACT standards
90/95% air toxics
reductions achieved from
enforceable commitment
sources
• [
1993 1994 1995
i
j
30% reduction goal
deadline (all media)
50% reduction goal
deadline (all media)
The Industrial Toxics Project (ITP)
Figure 6.—The Early Reductions (top) and 33/50 (bottom) programs.
States' largest estuaries. The watershed for this
bay spans six states along the Eastern Seaboard,
from southern New York to southern Virginia.
The bay has been polluted by both point and
nonpoint sources. As Figure 7 shows, air deposi-
tion accounts for approximately 47 percent of the
toxics either released or transferred into
Chesapeake Bay.
The Chesapeake Bay Program is an excellent
example of how the TRI is used to strategically
61
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Reporting Releases of Toxic Chemicals
Land
Water-
source = Toxic Release Inventory
Legend
Air
••Fugitive 11.0%
••Stack 36.1%
Water
EZJSurface 0.2%
Land
CZDUnderground
Injection 0.02%
C2S9On-site 5.2%
Off-site
15.5%
22.0%
Figure 7.—The Chesapeake Bay: releases and transfers of TRI chemicals.
approach the cleanup of a polluted waterbody.
EPA's Chesapeake Bay staff set the program up to
proceed on different levels. First, it identified
toxic chemicals in the bay's water, plants, and
animals. Then, three monitoring stations were set
up around the bay to confirm which pollutants
are entering the bay's ecosystem. These stations
mostly track air emissions.
Chesapeake Bay staff take the information
gained from analyzing the biota, the monitoring
stations, and the TRI along with other EPA and
state databases to identify potential point sources
of toxics. Figure 8 illustrates how different
databases provide many pieces to the Maryland
point source load puzzle. Maryland's state
database provides staff with estimates of the
number of municipal sources. After the state has
identified the potential sources through the TRI, it
uses computer models to verify whether these
sources could have contributed to the problem.
Figures 9 and 10 illustrate this process.
Figure 9 shows little progress between 1987
and 1988; however, Figure 10 indicates a more
positive picture after the 33/50 program is fully
implemented. Adding to these reductions are the
goals of the Clean Air Act Early Reduction Pro-
304(1)
(Industry
State
1 Municipal
Figure 8.—The Chesapeake Bay: Maryland point
source load estimates from different sources.
gram. Companies are just starting to commit to
this program, so it is too early to tell which reduc-
tions will directly benefit the Chesapeake Bay or
the totals. Merck (the pharmaceutical company)
and Du Pont's Chemical Manufacturing Division,
which have facilities in the six-state region sur-
rounding Chesapeake Bay, are two companies
that participate in the program.
62
-------
D.DEVOE
Millions of Ibs/year
160
I Fugitive
IStack
Off-site
EBPOTW
E£3 Other
Water
E23 Surf ace
Land
BS30n-site
Figure 9.—The Chesapeake Bay: TRI releases to dif-
ferent media, 1987-88.
Millions of pounds/year
uu
tin
mn
4O
in
Oil
£U
m
ft
•
%
///,
I
///
1
!^| '88 '93 '95 '88
Air Off-site
C]'88 a'93
Land
Water
Figure 10.—The Chesapeake Bay: projected 33/50
reduction.
The Great Lakes
The Great Lakes region of the United States, com-
prised of five lakes and eight states, shares a com-
mon border with Canada. EPA's Great Lakes
Program, in existence much longer than the one
for Chesapeake Bay, is another example of how
the TRI has helped focus efforts on an area. In ad-
dition to choosing priorities, the Great Lakes Pro-
gram has used TRI to target geographic areas of
concern that will take priority.
Program staff targeted sources from the TRI,
which will be curtailing emissions through the
33/50 multi-media programs, hazardous waste
sites on the National Priority List, and locations
where hazardous spills have occurred.
In Chicago/Gary, Illinois, and Detroit,
Michigan, the staff will use the TRI to reduce
emissions from area sources. The Early Reduc-
tions Program will also reduce toxic air emissions
in these targeted areas and to all the Great Lakes.
So far, EPA has commitments from Monsanto and
Allied Chemical plants in Region V. Both com-
panies manufacture chemicals.
Conclusion
This presentation has attempted to illustrate a
picture of the air toxics jigsaw puzzle in the
United States and explain how EPA is filling in all
of the pieces, both large and small, from the sour-
ces of air toxics to how the TRI data have helped
determine priorities for action and identify both
toxics and their sources.
I return you to this image because this is
where the United States started: an assessment of
the problem to draw the picture on the puzzle so
we can begin to piece it together.
Toxics — they pervade the land, water, and
air from sources too numerous to name, but they
are a universal problem. The solution, then, is up
to us. It takes creativity and determination to es-
tablish an inventory like the TRI. However, if we
learn from one another and fill in the jigsaw puz-
zle one piece at a time, we will have a multi-
pronged method of attack to identify and
ultimately eliminate toxics from our picture.
63
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The Toxics Release Inventory —
American Journalism's New Arrow
in the Quiver
Bud Ward
Environmental Health Center
National Safety Council
Washington, D.C.
ABSTRACT
The American media still are on a learning curve in their approach to right-to-know reporting.
Increasingly, however, environmental reporters use right-to-know programs and information to
better inform local audiences about potential chemical risks. The best journalists now recognize
that an emphasis on chemical release numbers alone is no longer sufficient. What do the num-
bers mean in terms of public health? What can be done to effectively manage releases? How
valid are year-to-year or plant-by-plant comparisons? How can the newly available TRI infor-
mation be used most effectively? These questions and more are leading reporters to increasingly
use right-to-know to better inform audiences. Right-to-know provides American media with a
valuable — and, used correctly — "straight" arrow in their quiver.
Environmental journalism in America has a
new and promising arrow in its quiver of
information resources as a result of data
now available — and gradually maturing —
under the Emergency Planning and Community
Right-to-Know Act, passed by the Congress in
1986.
Within that opening statement lie the major
points I hope to make about the American
media's use, non-use, and occasional abuse of the
motherlode of information available through the
Toxics Release Inventory (TRI) database. Let's
step back and take those points one at a time.
The first refers to environmental journalism
in America. Make no mistake about it; environ-
mental journalism is a permanent institution in
print and broadcast newsrooms across the United
States, just as environmental protection per se is a
permanent and ongoing domestic program
throughout this country.
American journalism has come a long way
since the time just 20 years ago when it was wide-
ly held that any reporter could cover any story on
a moment's notice — and do it well. Like its big
brother, science journalism, environmental jour-
nalism has developed into a refined and
respected specialty beat, with reporters specifical-
ly trained on the job to cover and communicate
effectively on the subtleties and nuances, the
shades of gray involved in that beat. Just partial
testimony to that point is the recently established
Society of Environmental Journalists in the
United States. This two-year-old organization
now claims nearly 600 members nationwide; its
first annual meeting, held in October 1991, at-
tracted more than 250 registrants notwithstand-
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Reporting Releases of Toxic Chemicals
ing severe financial difficulties and slashed travel
budgets facing the news media because of the
current economic slowdown.
The TRI — A New Resource
Enter the Toxics Release Inventory. Availability of
a computerized database on certain manufactur-
ing businesses' releases and emissions of more
than 300 hazardous chemicals comes to American
journalism as another trend is rippling through
American journalism schools and news organiza-
tions: computer-assisted reporting.
"Because that's where they keep the money."
That memorable response is attributed to famed
gangster Willie Sutton when he was asked, "Why
do you rob banks?" Former Providence, Rhode Is-
land, reporter Eliot Jaspin — widely recognized
as a pioneer in computer-assisted reporting in the
United States — makes essentially the same
response when asked why journalists should use
computers and databases in their reporting. "Be-
cause that's where they keep the information,"
Jaspin says. Plain and simple.
While TRI is an increasingly valuable
resource for American environmental journalists,
using it to inform citizens about potential chemi-
cal risks in their communities is a relatively new
phenomenon. In fact, the data are still embryonic
in terms of application, development, and poten-
tial. Computer-assisted reporting overall — and
effective use of the Toxics Release Inventory in
particular — is a bullish element in U.S. environ-
mental journalism. Most reputable environmental
journalists are just learning how to take better ad-
vantage of the fruits that can be harvested from
the TRI.
One can argue that the allure of the TRI, its
promise of riches to be mined for those willing to
do the exploring and digging, accounts in some
significant part for journalists' increased interest
in environmental news. The promises of more
responsible and compelling information through
TRI have made reporters more receptive not only
to mining those particular lodes but also the
riches of computer-assisted journalism, and,
therefore, to further honing their environmental
reporting skills.
If it is true that the temptation, the roman-
ticism, if you will, of dialing a distant database,
punching a keyboard, and downloading valuable
community-specific chemical information is at-
tractive to environmental reporters, what
products can we point to as emerging from that
interest?
It is important to underscore that this new
and promising information resource for American
journalists is just that — new and promising.
Reporters, editors, and graphic artists must fully
learn how to use this resource most effectively;
therefore, it will take time for the promise of
potential to become a full-blown reality. The good
news is that much progress has been made.
How Journalists Use the TRI
One thing we have learned is that major new en-
vironmental initiatives in the United States in-
evitably go through a lengthy and sometimes
trying gestation period. That is the case also with
journalists' use of this new arrow in their report-
ing quiver. Perhaps the most significant evolution
is that the TRI story has gone from being an an-
nual July 1 report based solely on numbers — the
millions of pounds of emissions and releases
reported by covered manufacturers — to being an
integral part of reporters' year-round reportage.
Decidedly, that does not minimize the recurring
annual stories on numbers alone but rather points
out that, along with those stories, we now see
more reporting, frequently in the form of a major
series or three- and four-part project feature that
integrates not only quantitative information but
also qualitative considerations. In effect, we're
seeing more and more reporting not only on what
TRI data are, but also, and importantly, on what
they are not.
That gradual but continuing maturation of
reporters' uses of Right-to-Know information
reflects both a growing sophistication on their
part in using and understanding the raw numbers
and, at the same time, one of their greatest
frustrations. What do the numbers mean? What
do they tell us about potential risks, both per-
ceived and real? The numbers alone do not easily
translate into answers to those most important
questions, and reporters and their editors increas-
ingly are aware of that shortcoming and
frustrated by that reality. Numbers are an impor-
tant part of the environmental story that
knowledgeable reporters want to tell their
audiences; however, reporters are loath to write a
story based solely on raw numbers.
The gradually maturing use of the TRI — not
only by reporters and editors but also by their
graphic arts departments — has the potential to
66
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bring so much more understanding and insight to
sheer words and numbers. Take a look at some of
the kinds of graphics presentations Right-to-
Know has helped bring to print media audiences.
Maps, pie charts, bar graphs, spreadsheets, line
graphs — all are features of the most informative
reporting done using the TRI. At their best, these
graphics can capture and communicate masses of
complex and otherwise abstract numbers and
polysyllabic chemical names; at their worst, they
can unjustifiably inflame and heighten needless
fears.
In that respect, the TRI database is like any
other major environmental program in the United
States and perhaps anywhere else in the world: it
offers great potential for effective use, but it can
also be misused and abused. However, in it and
through it, reporters and their audiences will find
new kernels of understanding, questions to be ex-
plored, and communications challenges to be
overcome for the benefit of a more informed
citizenry.
The most perceptive reporters will see enor-
mous potential in the TRI database for responsib-
ly informing audiences on actual and potential
chemical risks they may face in their com-
munities. They seek to derive every last ounce of
ft WARD
valuable and credible information from the TRI.
And, at the same time, these reporters will recog-
nize the inherent limitations of that same infor-
mation — limitations well known to all who
understand the data best in terms of flow rates,
exposure data, gaps and omissions, and timeli-
ness.
Conclusion
It would be foolhardy to pretend that the TRI is or
ever will be as much of an environmental
reporter's tool as, say, the telephone or personal
interview. It's not, and it's not meant to be, nor
will it ever replace a time-tested reporter's techni-
ques as a means of informing readers, viewers,
and listeners. But as a new and valuable informa-
tion arrow in their arsenal, the TRI already has
contributed much to environmental reporters'
growth and audiences' understanding of chemi-
cal risks in the community.
The best news is that, as the data mature,
TRI's role will expand and evolve along with the
environmental reporters' own responsible under-
standing and use of that information.
67
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If
Initiatives Generated
by the TRI
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Industry Initiatives at the National Level
• Earl Beaver
Waste Elimination
Monsanto Chemical Company
St. Louis, Missouri
ABSTRACT
As public perception about the environment evolves, companies with chemical operations find
it ever more important to voluntarily stretch their efforts beyond legal requirements.
Monsanto's approach to waste elimination is driven in large part by the size of the enterprise, its
diversity, and growing knowledge of its effects on the environment. Information such as the
Toxics Release Inventory and the analysis thereof lead to an ever-growing sense of voluntarism
regarding the environment. Monsanto's vision of corporate environmental stewardship is em-
bodied in programs to reduce 90 percent of toxic air emissions, obtain a 70 percent reduction in
all high priority wastes from chemical operations, and make the Monsanto Pledge a part of each
employee's approach to the job.
This presentation is a view from inside a
major corporation — a corporation that
was changed dramatically by events oc-
curring outside. Three voluntary initiatives are
presented here: a program for air emissions, a
program for multimedia emissions on a different
time table, and a comprehensive program — the
Monsanto Pledge.
Monsanto Company is a large enterprise with
approximately 100 sites around the world, 41,000
employees, and five very diverse operating units,
each diametrically different from the others. It is
an enterprise that, in 1987, released 18 million
pounds of materials judged toxic to the air — a
piece of information that was a shock to many
within the company.
In 1987, the total releases of organics and
toxic inorganics to air, water, and land were 350
million pounds. Also in that year, more than 1,000
Monsanto employees spent a majority of their
time working on environmental matters.
In the long history of legislation in the United
States, the passage of Title HI in 1986 was the most
important for Monsanto Company. Title in
enumerated substances in a list of materials that
sparked establishment of Monsanto's 90 percent
goal for reducing air emissions. It was a sig-
nificant event for Monsanto's employees when
our chairman told the world that the corporation
was committed to achieve this goal. Shortly after-
ward, in 1989, Monsanto Chemical Company, one
of the five parts of the corporation, committed to
making a 70 percent reduction in emissions to all
media — not just air — by the end of 1995. And in
1990, the corporation issued the Monsanto Pledge
(Fig. 1), which has an ultimate goal of zero effects.
The 90 Percent Program
The 90 percent air emission reduction goal for
Monsanto started from a base of roughly 18 mil-
lion pounds of emissions in 1987. As of last year,
data (in part for TRI reporting) showed that,
within the United States, Monsanto had achieved
a 58 percent reduction in listed materials. The cor-
poration appears on target to' achieve 90 percent
reduction by the end of 1992.
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Reporting Releases of Toxic Chemicals
m Reduce toxic and hazardous releases;
ultimate goal of zero effect
m No undue risk to employees and communities
m Achieve sustainable agriculture
m Ensure groundwater safety
m Open plant to community
m Benefit nature
m Eliminate waste from operations
Figure 1.—The Monsanto Pledge.
Many people in the corporation are highly
committed to the 90 percent reduction goal and
driven to accomplish it; however, some are con-
cerned because many projects take a long time to
define, get approved, get the large equipment on
order, and have it arrive, be installed, and start
up. Monsanto is confident that it will accomplish
the intent of this goal; however, the emission per-
centage may be 89, 92, or 93 percent, and it may
be accomplished in February instead of Decem-
ber. The effort is ongoing and the impact on the
environment will be reduced by approximately 90
percent.
Monsanto's original goal, which was based
on U.S. law and focused on U.S. operations, was
expanded rapidly to include compounds around
the world. Residents and officials of other
countries identified other toxic substances of con-
cern to them. Since then Monsanto has added
materials called "local concern chemicals" to the
list and undertaken a program to reduce them as
well. Progress is slower globally than it is in the
United States in part because of a late start and
also because of the large volume of some of these
local concern chemicals. Nevertheless, people in
plants outside the United States are as actively or
even more actively pursuing reduction of emis-
sions and their impact on the environment, in
part because of TRI.
The 70 Percent Program
The 70 percent program is different from the 90
percent program in several ways. First, it's a mul-
timedia program — it pertains to air, water, and
land. Second, the goal is a 70 percent reduction.
The challenges are some 20 times greater than
they are for air alone. And the third difference is
that, to date, this program focuses on Monsanto's
chemical company.
Prioritization mechanisms deal with wastes
and methods for treating them. Division coor-
dinators — people within each division and busi-
ness who are experts in operations, business, and
nature of the materials released — are account-
able for the performance of their individual
divisions on waste elimination. Monsanto also
has an informal network of staff persons who
have taken responsibility to do something about
the amount of waste. A steering committee, con-
sisting of four vice presidents and two staff, meets
regularly to discuss major policy issues.
Monsanto has an internal priority system that
ranks a substance's priority on a scale of one
through five. Priority one includes materials, such
as those on the SARA list. We judged a few sub-
stances more hazardous than those on that list, so
we added these chemicals and deal with them.
After all, we know more about those streams than
do the regulators.
Monsanto also uses a familiar hierarchy of
methods for dealing with wastes. For us, the most
important thing is to put in alternate product
technology, for example, improving yield from
converting raw materials into products. If 500
million pounds of adipic acid is produced annual-
ly, increasing yield by 1 percent gives five million
more pounds of things that you can sell in the
marketplace — along with five million less
pounds going to the environment.
The Monsanto Approach places a relatively
high priority on recycling and reusing materials
and on selling the byproduct or coproduct. You
might call these things "waste"; however, if I
show up in your office with a brochure to sell you
something that would normally be called a
"waste," I'm going to call it a "coproduct" — a
product of high purity and high quality that is
ideal for your needs!
Monsanto's lowest priority is the destruction
of material because that in itself is a waste. We
give higher priority to those steps that will even-
tually allow progress beyond 70 percent reduc-
tion.
In the corporation, we have enumerated rules
for how to "count" things and what to do with
them. The rules are simple and easily understood.
Our rules are on a process, not a site or a business,
basis. They focus on recurring activities, those
things that continue and have a significant effect
on the environment. Other staff deal with events
or spills. We focus on released materials for air
and generated materials for liquids and solids.
Calculations are done on a dry weight basis.
72
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£ BEAVER
Monsanto has rules for other companies that
operate on our sites; we don't let them get away
with practices that are not acceptable to us. Those
residents who live outside the fence of a Monsan-
to facility don't care who owns the plant in the
middle. What they're concerned about is the ef-
fect on the environment.
There have been a few surprises along the
way. In Figure 2, the vertical axis is total reduction
as a cumulative percentage. The horizontal axis is
the cost in capital dollars per pound reduced.
Notice the shape of the curve; it drops
precipitously at first because some of the things
that were done early on were inexpensive. But
notice something else, that the intercept of the
curve doesn't occur at zero but at -10 because 10
percent of the reduction was free. During the in-
troduction of the program, employees were told
the objectives and they changed their operating
practices. Some waste reduction was achieved for
zero capital cost. But also notice the other end of
the curve. At the 70 percent level, it's starting to
get expensive, and, if you push things to 75 per-
cent, it's very expensive.
Now that's the way things looked in 1990, but
the lines have shifted. We got smarter; one year
CUMULATIVE % REDUCTION
later, we discovered that we had figured ways to
do things just a little cheaper than our estimates.
Within Monsanto, there is tremendous com-
petition for resources. The person asked to reduce
the waste is the same person who is trying to
make the product more "white" (purer) so it will
sell better and is also trying to save energy and
improve the yield.
More capital is spent on Monsanto's air pro-
gram, per pound, than on the other programs.
Also, there's an imbalance of capital expenditure
versus operating expense versus risk because
we've set deadlines and driven people to ac-
complish them. On occasion, people will spend
more money for capital than is required to
achieve higher certainty.
The programs differ inside Monsanto's
various operating entities. We are working to iron
them out so that someone from Monsanto Chemi-
cal Company won't say one thing while someone
from Monsanto Agricultural Company says
another.
Monsanto is a chemical company by history,
so it has the best solutions for concentrated
chemical wastes — but also the least-developed
-804
0
2 4 6 8 10 12 14 16
CAPITAL COST PER LB. REDUCTION-$/LB.
18
-»- 1990 ESTIMATE
Figure 2.—Total waste reduction versus cost
1991 ESTIMATE
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Reporting Releases of Toxic Chemicals
resolutions for dilute wastes, which require
biological solutions.
Along the way, we've discovered a number of
public and international issues. One is that, by
making our situation public, we attract help:
people find out what our situation is and come to
our aid by offering solutions (sometimes by offer-
ing to sell us things). We gain support from our
employees because, if we mail the Environmental
Annual Review (our "green book") to everybody in
the community and the neighbors read it, they
talk to the Monsanto employees and say "Get on
with it! We want to see those numbers go down in
future issues."
Monsanto endeavors to be a global corpora-
tion. In the green book, we do not say U.S. and ex-
U.S. Instead, we say "global." We've included
local concern materials in our programs because
we probably didn't get the list right in the United
States.
Today, Monsanto has three initiatives: a 70
percent program, a 50 percent program in the
agricultural company, and a 90 percent program
for air. What is under consideratin and referred to
in our green book is a uniform corporate-wide
program for all emissions.
The Monsanto Pledge
The Monsanto Pledge contains a number of ele-
ments. The words were written by wordsmiths,
but frankly, the intent is there, and it says that we
will be good corporate citizens wherever we do
business. Focus on the last line: "We will
eliminate waste wherever we have operations by
finding the best possible technology." That's my
job.
Conclusions
External publication enhances employee commit-
ment. Publishing statistics, telling the world
about them, standing up in front of the public and
explaining the data makes employees work hard-
er. The result is obvious progress in waste reduc-
tion.
When talking publicly about our corporate
commitment, we attract people who have truly
innovative and creative solutions.
We write goals for our people — waste
elimination coordinators and those in the en-
vironment — that incorporate our expectations.
Constant support from Monsanto's top
management is essential to its program.
Managers participate in reviews and, frankly,
they must react to the presentation.
International uniformity in regulations ap-
plied to the chemical industry is very desirable.
For companies like Monsanto, dedicating re-
sources to meeting a myriad of different regula-
tions is, generally, a poor use of resources.
Uniform lists of materials and practices allow
companies to turn energies and efforts to actually
eliminating waste.
Implementation of TRI practices has triggered
and catalyzed a visible change in Monsanto Com-
pany — and in other responsible companies in the
chemical industry.
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Local Initiatives in TRI Reporting:
The SCORECARD Model
Paul L. Hill
National Institute for Chemical Studies
Charleston, West Virginia
ABSTRACT
In 1986, the National Institute for Chemical Studies (NICS) began working with residents of
West Virginia's Kanawha Valley to assess emissions from local chemical plants. Because chemi-
cal facilities had claimed decreases in emissions, community residents wanted a credible report
to evaluate these assertions. NICS invited government representatives, environmental activists,
and industry leaders to discuss a reporting mechanism for the evaluation, and SCORECARD
was born. NICS, a non-aligned third party, prepares the report, and a broad-based advisory
committee assures that the concept, format, and information are balanced and acceptable to the
general public. The Toxics Release Inventory reporting serves as the basis for NICS' annual
SCORECARD and is supplemented by voluntary submission of both facility descriptions and
emission data by state chemical facilities. SCORECARD is unique because the cooperation
fostered by NICS has allowed timely community access to credible and comprehensive informa-
tion about industry success or failure to reduce emissions of toxic chemicals.
Introduction
The National Institute for Chemical Studies
(NICS) was founded in early 1985 by West Vir-
ginia business, labor, and government leaders,
academicians, and others seeking ways to reduce
risks posed by chemical plant operations and, at
the same time, support continued economic
growth. NICS is neither an industry-based trade
association nor a quasi-public agency with
regulatory or enforcement powers. Nor is it an en-
vironmental advocacy group. NICS' unique func-
tion begins with the basic premise that the public
plays an important role in the management of
chemical risks.
NICS is a nonprofit organization. Financial
support is broad-based, coming from federal and
state government, local business, chemical com-
panies, and foundations.
In 1986, NICS began working with residents
of West Virginia's Kanawha Valley to assess emis-
sions from the numerous local chemical manufac-
turing facilities. The valley is also home to the
largest United States producer of methyl
isocyanate (MIC), the chemical compound iden-
tified in the Bhopal, India, disaster in 1984.
Kanawha Valley residents were thus alarmed by
the potential for both short-term disasters and
long-term health problems related to this local
concentration of chemical manufacturers.
Because chemical facilities began publicly
reporting their efforts to reduce routine emissions
as well as the potential risk of accidents, valley
residents requested some mechanism for annual
tracking and verification of their progress. They
also pressed for right-to-know legislation, which
is now in place across the United States. Right-to-
Know, or the Emergency Planning and Com-
munity Right-to-Know Act (EPCRA), required
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Reporting Releases of Toxic Chemicals
emissions data reporting, but the community
wanted a customized report for the local area.
NICS, as a third party, brought together in-
dustry, government, and environmental and ac-
tivist groups to discuss development of such a
mechanism. The term "scorecard" was chosen by
the broad-based committee to reflect what they
envisioned. In essence, they wanted to compara-
tively score the environmental emissions of the
chemical facilities.
Getting Started
Putting together a well-balanced advisory com-
mittee was not easy. NICS sought a commitment
from all parties that they would be willing to
work toward progress for a mutually agreeable
reporting system not overly burdensome to any
party. At the same time, all agreed to keep, in
mind that no formal system existed for generating
emissions data. The committee spent almost two
years developing a mutually agreeable format for
reporting data.
One of the key components for NICS was
securing corporate commitments both to reduce
emissions and participate in the SCORECARD
program. NICS gained the voluntary endorse-
ment of corporate chief executive officers before
developing the first report, much as the U.S. En-
vironmental Protection Agency (EPA) is doing in
the United States today with the 33/50 Program.
After several months, the committee agreed
that chemical facilities should provide
• data on emissions to air, water, and land,
• a narrative that described what pollution
prevention steps were being taken at the
site and how these were reflected in the
data, and
• goals for further reduction.
Collectively, these items would shed light on both
short- and long-term commitments of the com-
panies involved and provide a public record to
scrutinize industry efforts.
The advisory committee specified that chemi-
cal compounds should be separated into two sec-
tions: carcinogenics and other toxics. A third
category, nontoxic wastes, was added. Although
everyone unanimously agreed that at-source pol-
lution prevention was the ultimate goal for com-
panies, the committee felt the community would
be best served by assessing all reduction, treat-
ment, and management practices being used by
chemical manufacturers. Committee members
agreed that this information would also shed light
on other issues, such as costs, technological suc-
cesses and failures, and trends for certain produc-
tion units or types. In the final analysis, they felt
the community had a right to this information
and a right to comment on it.
A major stumbling block for the committee,
however, was the lack of standard emissions
reporting protocols. At the time, companies calcu-
lated emissions using various formulas and
equipment, with no government specification or
oversight. The committee's problem was how to
make the information uniform so that all facilities
provided readily comparable data.
Toxics Release Inventory (TRI)
Availability
As a result of EPCRA, the first TRI data became
available in mid-1988. This system of reporting on
the levels of pollutants released solved many of
the problems encountered by the committee. It
standardized methods for data generation and,
because data had to be reported annually,
provided a continuous method for tracking in-
dustrial facilities' progress or lack of it. NICS is
finding that companies more readily volunteer to
participate in the SCORECARD program because
they are required to submit data to the U.S.
government.
TRI also solved the problem of which chemi-
cals to list and track through the SCORECARD.
Because EPA had compiled an extensive list of
chemical compounds, the SCORECARD Commit-
tee simply subdivided this group as previously
described, tracking a group of carcinogens of
local concern in Section A and tracking all other
TRI data in Section B. It retained the right, how-
ever, to suggest additional chemicals in the fu-
ture.
The First SCORECARD (1989)
By using the 1987 and 1988 TRI reports, NICS was
able to conduct statistical comparisons of the 11
major chemical manufacturers in the Kanawha
Valley for the two-year period. Companies were
requested to submit their data directly to NICS
when filing the reports with ,EPA. In this way,
NICS gained much quicker access to the data and,
consequently, could report more timely data to
the public.
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P.L HILL
The first SCORECARD, which was supported
by private foundation grants, was published in
December 1989. The initial report showed that
local companies had decreased carcinogenic pol-
lutants by almost 6 percent with a net overall
decrease in toxic compounds of about 2 percent
from 1987 to 1988. While these reductions were
not impressive, they established a baseline to
judge future claims and, more importantly,
provided a plant-by-plant review of what the
companies were doing to prevent pollution and
publicly established goals for future reductions.
Numerous statistics and graphics for water, land,
air, and off-site disposal also were generated for
the first time.
The Second SCORECARD (1990)
The second SCORECARD built upon the baseline
report and compared TRI data from 1987, 1988,
and 1989. Further analysis revealed a 25 percent
reduction in carcinogenic pollutants from 1987
levels, while overall environmental discharges in-
creased almost 20 percent. The increase was at-
tributed to more stringent reporting requirements
of EPCRA, market changes, and increased
production. A primary finding of the report was
that companies were focusing on the pollutants of
greatest public concern — the carcinogens. The
public demand for decreases in this category has
brought about positive and responsible action by
the facilities.
Expansion of the SCORECARD
Model
NICS has now expanded Kanawha Valley's
SCORECARD to include chemical manufacturers
from the entire state of West Virginia. Twenty-
three facilities are now participating in the pro-
gram, which seeks to further expand the use and
comprehension of TRI data. Industry and en-
vironmental organizations alike have asked NICS
to expand the program, which is now supported
by an EPA grant.
Environmental activists have commented that
they view the report as supporting documenta-
tion that can be used in directing their criticisms
and/or praise to facilities that have a poor or
noteworthy performance record. Before SCORE-
CARD, facilities had data (now a matter of public
record) synthesized and interpreted by various
groups and individuals; there was no commen-
tary, explanation, or dialogue from industry. Be-
cause this led to inaccurate and one-sided report-
ing, facilities from other states and regions have
expressed interest in SCORECARD, which is a
balanced mechanism for discussing and interpret-
ing TRI data.
NICS is currently expanding SCORECARD to
other regions across the United States. However,
the data are often found to be most useful when
customized into regional or local reports that ad-
dress and summarize information to meet
citizens' needs. By developing a factual, scientifi-
cally credible report for smaller geographic
regions, community leaders, local industry, and
environmentalists can work together for progress
in their own communities, states, or regions.
Industry Initiatives
The chemical industry in the United States has
recently taken a proactive stance on communicat-
ing with the public regarding emissions and
sources of public risk. Chemical industry councils
(CICs) have been formed (or are forming) in most
states that have chemical manufacturers. The
CICs and other state associations are encouraging
compilation of documents similar to SCORE-
CARD. The Baltimore, Maryland, CIC and
Louisiana Chemical Association's compilations of
TRI are good examples of this type of effort by in-
dustry.
What those documents contain, however, is
usually not governed by a citizen-government-in-
dustry committee with balanced points of view,
so the results are usually greeted skeptically by
the public. Likewise, reports by strong environ-
mental advocates are questioned by the public —
but to a lesser degree. NICS's balanced approach
and straightforward interpretation provide the
most acceptable mechanism for public com-
munication of TRI. By establishing the National
Institute for Chemical Studies as a nonaligned
third party, we have generated trust and
credibility with all parties. This process, in turn,
makes TRI meaningful and useful for local public
involvement in continuous TRI reduction and
pollution prevention.
Recap: Why SCORECARD's
Process Works
The National Institute for Chemical Studies'
SCORECARD:
77
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Reporting Releases of Toxic Chemicals
I Provides an understandable discussion and
analysis of TRI (narratives included with
the data assist in interpretation),
Works directly with chemical facilities,
with faster local reporting than through the
national database,
Gives regional and local analyses of data
that are meaningful to those most affected
by emissions,
Empowers communities to encourage pol-
lution prevention,
Creates some competition among com-
panies to do a better job,
Makes company goals and commitments
public,
Involves the public in generating and over-
seeing the report,
Gains better acceptance as a credible report
when published by a third party with assis-
tance from a broad-based advisory commit-
tee, and
Provides a model easily adapted to other
geographical areas.
78
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Public Initiatives at the National Level
Warren Muir
Hampshire Research Associates, Inc.
Alexandria, Virginia
ABSTRACT
Under section 313 of the Emergency Planning and Community Right-to-Know Act, the U.S. En-
vironmental Protection Agency is required to make industry-submitted Toxics Release Inven-
tory data available to the public through telecommunication with a computer database and by
other means. Numerous reports with a national focus have been prepared using these data. This
presentation will discuss some of these reports and their impacts.
A few years ago when the Toxics Release
Inventory (TRI) had just been enacted
into law and before the first data were
collected, EPA asked Hampshire Research As-
sociates, Inc., to help figure out what, in addition
to the legal requirements, would be the best ways
to get the information out to the American public.
In response, Hampshire Research phoned 150
persons and groups at all levels and locations
around the country — everyone from lawyers to
local government officials to scientists — to ask
"If you had this type of data, would you be able
to use it, how would you use it, and what would
be the best ways for you to get the information?"
The most significant conclusion from that
study was that these particular data have un-
bounded uses and users. At the national, regional,
state, and local levels, there is interest in informa-
tion about chemicals, industry, and the other
types of data available from the TRI. We could not
define any limited number of most important
uses or most important users because there was
such an unbounded array.
Indeed, that has still proven to be the case
now that three years of data are available in the
United States. Data have been the basis of volun-
tary industry programs. Boards of directors have
been seeking data about their companies and the
rest of the industry to see where they stand in
relation to other similar companies. Congress not
only enacted the Toxics Release Inventory but ex-
panded it with pollution prevention legislation
and provisions for early reductions in the Clean
Air Act that are, in part, grounded in TRI.
Law firms have been using TRI to find defen-
dants. States have been incorporating TRI as the
basis for integrated permitting approaches, for as-
sessing taxes, for targeting technical assistance
programs, and for establishing pollution preven-
tion planning programs. Those states particularly
high in TRI releases are using TRI as a rationale to
establish stronger pollution control programs.
Environmental groups have been using TRI
to identify important targets and set priorities
within states. TRI has influenced Ohio Citizens
Action, an environmental group, to focus many of
its activities in support of a local group in Lima,
Ohio, where the British Petroleum plant is by far
the largest source of TRI releases and transfers in
the state.
TRI data have been used to create reports on
air pollution — a report card on a company, to
look at why changes are occurring in TRI, inter-
state transport of waste, and what is not being
reported to TRI. Other companies look at the
relationship of TRI releases and transfers to
socioeconomic patterns to determine whether cer-
79
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Reporting Releases of Toxic Chemicals
tain ethnic, economic, or racial groups are dis-
proportionately associated with high concentra-
tions of TRI releases and transfers.
Some people have looked at the releases and
transfers in conjunction with number of pounds
per dollar of sales in various industries. And
some industries and outside groups have incor-
porated TRI data in product lifecycle analysis; in
other words, they look at what pollution is as-
sociated with the production of one type of
material versus an alternative type.
EPA's National Report
Hampshire Research has been involved in the
production of EPA's national report on TRI data.
Each year, EPA has issued a book, such as the 1987
report, Toxics Release Inventory — A National
Perspective. This publication includes literally
hundreds of tables and charts, loads of maps, and
analyses that try to provide most national and
state perspectives on TRI data. Each year
Hampshire Research picks and chooses to feature
slightly different types of information.
All the data used to prepare this report are
available to the public as we prepare the report. In
fact, that's a bit of a problem because producing a
report of this size takes a few months; meanwhile,
anyone else can get the data and quickly publish
summaries. So we always try to include some uni-
que features each year in the report.
Hampshire Research is not doing anything
when producing this report that the public cannot
do. Indeed, this firm does not possess a
mainframe; we produce virtually the entire book
and all the analysis on our office personal com-
puters — and you can, too.
This report gets through EPA review relative-
ly easily because all the data are available to the
public. If we tried to include some special
analysis or reflect some bias, we would be imme-
diately subject to independent review by the
public. In the report, the facts are the facts.
If we don't name the top 50 facilities. Clean
Water Action or someone else will — so we put
them in. No particular policy spins are put on this
report, which basically lays out the data. In fact,
one of the unique features about TRI is that
there's no way that EPA can control the spin on
this database. TRI data are just out there and
Hampshire Research and EPA are analysts and
users like anybody else.
Report Features
Certain features of the TRI report have proven es-
sential for the success of this program. The report-
ing is done on a specific chemical basis — the
only relevant way of handling the multimedia ap-
proach. Look at the TRI list; nothing there invol-
ves reporting on mixtures or undefined materials
(no reporting on turpentine or complex process
wastes or other like chemicals). So we're looking
at the full range of ways these materials are enter-
ing the environment.
Trade secrecy provisions are narrow. Over the
last three years, nearly 250,000 forms were filed in
the United States, but only 25 are now held con-
fidentially. Even then, we know who made the
claim and how big the releases and transfers are;
in fact, we know everything but the exact chemi-
cal name.
The reporting is highly structured and stand-
ardized. It allows for easy generation of bar
charts, pie charts, and aggregates. With TRI, data
can be used in a wide variety of contexts and easi-
ly turned into computerized graphics. Also, the
data can be actively disseminated to the public.
Almost all of the air, water permit, and haz-
ardous waste permit information is available to
the public in the United States. However, these
data may be in files, in written form, poorly
copied, or on a pile on the floor. The information
is certainly scattered all over this country. To try
to get a uniform picture from what is publicly
available is a next to impossible task. TRI pulls
the data together in a single location.
TRI is independent from pollution control
provisions; in other words, the listed chemicals
are not tied to regulations. Therefore, the data are
not distorted by the priorities, policies, and
nomenclatures in our various, rather incom-
patible pollution laws. Lastly, TRI provides a
computerized public record of revisions.
Ways to Improve TRI
TRI would be dramtically strengthened by the in-
clusion of six data elements that add important
throughput information: namely, the amount of
the material coming into, going out of, and being
produced and used up as reagent at the plant as
well as the beginning and ending inventories for
materials.
A number of important industrial toxic
chemicals not on the TRI list should be included.
The scope of TRI reporting should be expanded
80
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W. MUIR
internationally. Also, other industries not on the
list that are equally important contributors should
be included. In the United States, government
facilities are not required to report and, certainly
in many states, they are the major contributors of
toxic pollutants, so they should report under TRI.
less Important Aspects
Some aspects of TRI have proven less important
or less of an obstacle than originally expected.
When Congress was briefed about the pos-
sibilities of TRI, it was skeptical because the data
were based upon industries' best estimates as op-
posed to required numbers. Experience has
shown that this is not a problem.
EPA cannot control how TRI is perceived and
used or prevent people from misusing the infor-
mation. However, the Agency can help people use
TRI data. In addition, public education is not as
important as once thought to the success of the
Toxics Release Inventory.
Lastly, risks have not proven to be as impor-
tant as we thought, and pollution prevention has
become more important, especially reporting
treatment efficiencies.
Conclusion
How practical is TRI? TRI contains information
about industry that companies should know
about their operations. TRI is the lowest-cost way
found to date to achieve major environmental im-
provements. The costs to industry are often fully
offset by pollution prevention savings.
TRI does not require major computing
capabilities. Hampshire Research can handle the
entire TRI in the United States on its microcom-
puters. Certainly any of the countries in Europe
could handle the same data on such a computer
as well.
Much has been learned from the TRI. The
proposed 1991 Form R is a valuable starting
point, as is the TRI list of chemicals. The TRI is a
demonstrated success and most multinational
companies are already experienced in TRI report-
ing.
In sum, the TRI is a compelling new approach
to environmental improvement that is broadly
applicable around the world.
81
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Public Interest Group Initiatives
at the Local Level
Ted Smith
Silicon Valley Toxics Coalition
San Jose, California
ABSTRACT
In August 1988, the Silicon Valley Toxics Coalition was the first group in the United States to
compile and publicly release data from the new Toxics Release Inventory. The data — which
documented millions of pounds of toxics released into the environment by the largest and most
famous Silicon Valley electronics giants — were reported by the media throughout California
and the United States. This coalition urged the self-described "clean industry" to drastically
reduce its chemical use and emissions (particularly the CFC 113 discharges that proved to be the
largest in the nation). Since then, and after other significant national media attention, the high-
tech industry has significantly reduced its reliance on CFCs. In addition, the Santa Clara County
Manufacturers Group — the local trade association for the Silicon Valley industry — began
publishing an annual report in 1989 that documents its annual emissions as reported under TRI.
Production of synthetic chemicals in the
United States, which became a significant
industry in 1918, has expanded enormous-
ly since World War II. Figure 1 graphically depicts
this escalation and highlights industrial usages of
synthetic chemicals, including high-tech elec-
tronics.
Until rather recently, most people in the
United States and throughout the world thought
that the electronics industry was not part of the
toxics release problem — that it was, as self-
described, a "clean" industry. However, over the
past decade we have learned that the "clean" in-
dustry was in fact highly polluting. More Super-
fund sites are located in California's Silicon Valley
— a hotbed of high-tech industry — than
anyplace else in the United States. (Superfund
sites are so polluted that the U.S. Environmental
Protection Agency (EPA) has put them on a
priority list for cleanup.) Groundwater pollution
at 29 of these sites directly stems from the use and
misuse of solvents used in high-tech industry.
In addition, a high incidence of air pollution
and ozone depletion from these industries, as
well as occupational health hazards, has been
noted. Occupation-caused disease among semi-
conductor workers is about three times that of the
national manufacturing average.
Introducing Right-to-Know in
Silicon Valley
In response to this situation, the Silicon Valley
Toxics Coaltion produced a booklet, The Legacy of
High-Tech Development: The Toxic Life Cycle of Com-
puter Manufacturing, which states that the in-
dustry presents some significant problems. We
were able to determine this through, the develop-
ment of the right-to-know movement in the
United States, of which the Toxics Release Inven-
tory (TRI) is but one aspect.
You might think that right-to-know legisla-
tion was introduced without difficulty. In fact, it
has a rich history of struggle in the United States
dating back to the 1970s when, coming out of the
labor movement, the concept of worker right-to-
know was introduced in the first attempt to pry
83
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Reporting Releases of Toxic Chemicals
WS >*?S I*1S IMS l»55 IMS 1*75
knows nOKOte year when mot become luffneflriy "uomiicant' to be
mdudod gs speak tmeoarws m CommsKn teems.
Source: U.S. imtrnotiOMl Trade (ommssion
Figure 1.—Production of synthetic organic chemicals in the
United States from 1918 to 1976. Arrows Indicate year when
usage became sufficiently significant to be Included as specific
categories In Commission reports. Source: U.S. International
Trade Commission, 1978.
loose toxicity and chemical information and or-
ganize to combat industrial diseases.
This difficult, laborious process took place in
many different industries. Mining is one of the
main examples, with its high incidence of black
lung disease. The community right-to-know
movement started at the local level in the early
1980s when communities began developing and
passing right-to-know ordinances.
The Silicon Valley Toxics Coalition was one of
the first groups to pass a right-to-know or-
dinance, back in 1983. We had to overcome sig-
nificant resistance from industry and govern-
ment, who were uncomfortable with the notion of
making this kind of information public for a
variety of reasons, including concerns about
proprietary or trade secrets. (Industries also cited
additional paperwork as a possible problem.)
When we started organizing for right-to-
know ordinances in the Silicon Valley, some com-
munities and industries drafted a proposal that
requires companies to report toxics information to
the local government but made it a crime to dis-
tribute that information to the public. We had to
organize to overcome that type of approach and
eventually ended up with a local right-to-know
ordinance in 1983 that became California
law in 1985. Subsequently, the federal
government picked up the idea.
Our history with federal right-to-
know dates back to 1988, when the Coali-
tion compiled and released data to
dramatize some of the hazards associated
with high-tech production technology to
the Silicon Valley and communities
across the country. This was long before
EPA had compiled the data — or
anybody else for that matter. We didn't
have access to a computer system; we got
a box-load of paper from our state agency
and sat down one weekend and typed in-
formation into a personal computer using
a database program. This information
showed beyond a doubt that millions of
pounds of toxics were being released, dis-
charged, and transported off-site from a
relatively small number of companies.
Initially, we compiled a list of 25
companies. When we surveyed the top 12
companies in Silicon Valley, we found
they were releasing millions of pounds of
toxics, data that we put in a report and
gave to the media (Table 1). Because this
shocking information was being reported
for the first time, it received quite a bit of atten-
tion. Some of the following information was
presented:
Twenty-five major area companies are dumping
millions of pounds of toxic chemicals into the environ-
ment each year according to data recently filed with
EPA and the California Office of Emergency Services.
This new information, required pursuant to Title III of
the Superfund Amendments of 1986, is now publicly
available as of July 1, 1988. The composite data for
Silicon Valley reveals that 25 companies with 41
facilities in Santa Clara County admitted discharging
over 12 million pounds of 34 different toxic chemicals
into air, land, and water. Almost 2 million pounds
went to the air through stack emissions, another 2 mil-
lion pounds were classified as fugitive emissions, and
about 8 million pounds were discharged into sewage
treatment plants or otherwise disposed of.
Under the current legal regulations, this type of
pollution is largely legal although considered immoral
by many. The Silicon Valley Toxics Coalition has
charged that industry has enjoyed a free ride to use the
air as an open sewer for its waste disposal and has is-
sued a call for industry to implement toxics use reduc-
tion and source reduction measures to cut down on
their use and disposal of these chemicals.
84
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r. SMITH
Some companies are already beginning to respond
to community pressures in other parts of the country.
Monsanto, for instance, has acknowledged almost 18
million pounds of discharges nationwide but has
promised to reduce those emissions by 90 percent in
four years and is approaching a zero discharge or zero
tolerance stance.
Table 1.—The TRI "Dirty Dozen" for Silicon Valley
for 1987-88 reporting years.
NAME
IBM
Xidex
UTC
National Semi
South Bay Circuits
Hewlett Packard
Lockheed
Siliconix
LSI Logic
Del Monte
Advanced Circuit Tech.
FMC
1987 + 1988 TOTAL
RELEASES (Ibs)
2,798,000
2,237,000
1,955,000
1,630,000
1,477,000
1,214,000
1,198,000
1,140,000
996,000
781,000
778,000
609,000
Source: Title 22-TRI Data
We also publicized our letter to IBM, urging it
to follow Monsanto's example — to disclose their
yearly emissions of freon worldwide and pledge
prompt phaseout of these ozone-depleting chemi-
cals. IBM's San Jose plant listed more than 1.3 mil-
lion pounds of ozone released into the
atmosphere, which turned out to be the largest
single source that we have uncovered. This
material can be found in our booklet. The Citizen's
Guide to the New Federal Right-to-Know.
Next, we compiled two years' worth of data
on combined releases, showing that companies
that had been deemed largely "clean" were in
reality releasing millions of pounds of pollutants
into the environment.
An interesting sidelight concerns a company
called Advanced Micro Devices. When we pub-
lished our initial list, this company's releases —
over 2 million pounds in the first reported year —
placed them at the top of our list. The company
took great offense at this and, to restore its
credibility, placed a full-page newspaper ad to ac-
cuse the Coalition of deliberately distorting and
misstating the information. Fortunately, EPA also
saw this ad and looked into its records, where it
discovered that we had simply published EPA
data. The Agency then wrote a letter to that effect,
which helped set the record straight. Advanced
Micro Devices later filed amended reports with
release data that removed it from the "Dirty
Dozen" list.
Using Right-to-Know Information
The Coalition used right-to-know information not
only to publicize and dramatize the problems but
to put out some challenges to local industry and,
in particular, to companies that were discharging
the largest amounts of chlorofluorocarbons
(CFCs) — the largest source of the discharges into
the atmosphere.
Table 2 is a compilation of the 1987 data, by
chemical, on the companies in Silicon Valley. We
took this information — particularly the IBM data
— and, on Earth Day 1989, organized a large rally
with other groups in front of IBM's plant gates
and invited Ralph Nader, a well-known environ-
mental and consumer advocate in the United
States, to speak. We challenged IBM to adopt ag-
gressive goals and timetables to completely
eliminate CFCs.
At the time, IBM didn't have much to say; it
was not ready to set phaseout goals and
timetables. However, IBM reported to the media
that it would comply with the Montreal Protocols
— the international treaty to phase out CFCs —
which would take effect in the year 2000. The
Coalition replied that, because of the huge
volume IBM was discharging, it should set an ex-
ample and take much more aggressive action.
By Earth Day 1990, IBM had come up with a
new program. It committed to an aggressive
phaseout of CFCs, not only in San Jose but
worldwide, with a phaseout date of 1993, which
at that point was the most rapid of any of the
major electronic companies in the world. IBM also
invited the Coalition and other groups to tour its
Silicon Valley plant and view a new process that
ultracleaned disk drives without using CFCs, just
soap and water, a fairly low-tech solution to an
enormous environmental concern. Now, IBM is
rapidly phasing out the use of that class of chemi-
cals.
We surveyed the 25 largest CFC dischargers
in northern California, asking them for goals and
timetables for complete phaseout of CFC produc-
tion processes. We then published a list of com-
panies that had set aggressive goals and
timetables and those that hadn't and called them
85
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Reporting Releases of Toxic Chemicals
Table 2.— 1987 data on
CHEMICAL NAME
Freon
TCA
Hydrogen chloride
Acetone
Methylene chloride
MEK
Xylene
Styrene
Tetrachloroethylene
Sulfuric acid
Methanol
Sodium sulfate
Phosphoric acid
Sodium hydroxide
Hydrogen fluoride
Glycol ethers
Phenol
Aliminum oxide
Nitric acid
Copper &
compounds
Hydrochloric acid
Ethylene glycol
TOTAL2
chemical emissions from Silicon
FUGITIVE
EMISSIONS
(lb»/yr)
1,448,299
316,212
0
100,675
73,220
31,489
15,055
27,000
29,800
0
8,500
0
102
0
0
0
0
0
0
0
0
0
2.062,277
STACK
EMISSIONS
(lb«/yr>
376,710
440,132
274,065
94,745
110,010
64,713
42,566
3,800
0
28,888
6,200
9,283
7,677
6,577
6,300
4,776
3,900
0
0
0
0
0
1,975,994
Valley Industries.
TOTAL
AIR
EMISSIONS
1,825,009
756,344
274,065
195,420
183,230
96,202
57,621
30,600
29,800
28,888
14,700
9,283
7,779
6.577
6,300
4,776
3,900
0
0
0
0
0
4.038,271
OTHER
DISCHARGES ft
OFF-SITE
DISPOSAL1
20,142
191,452
0
196,577
13,642
54,939
111,872
0
0
274,074
52,600
2,969,326
86,226
425,060
61,849
76,030
11,600
395,381
84,961
73,714
53,500
43,125
4,926,804
TOTAL
1,845,151
947.796
274,065
391,997
196,872
151,141
169,493
30,600
29,800
302,962
67,300
2,978,609
94,005
432,437
68,149
80,806
15,500
395,381
84,961
73,714
53,500
43,125
8,965,075
1 Including discharge to sewage treatment plants
2 Total includes category "others"
"leaders and laggards." Laggards were largely
defense and aerospace contractors who were
hindered by military specifications that required
using CFCs. Military standards continue to be a
big problem in the United States. The Coalition is
trying to help speed up the process whereby the
military will revise those specifications.
After we generated a number of reports that
focused on emissions and called for reductions,
the Santa Clara County Manufacturing Group, a
trade association that represents most of the
electronic manufacturing companies in our area,
decided to start compiling this information and
putting their own spin on it to publicize emission
reductions. For the last couple of years, it has
been publishing a report that identifies specific
reductions by chemical and plant.
We've come a long way — from the initial
resistance and hostility to the point where in-
dustry is purring out emission reports. In some
cases, some of these reductions can be as simple
as housekeeping — putting lids on solvent tanks
or educating employees about handling solvents
— and process changes that can be accomplished
with relative ease. Of course, in some significant
areas, solutions will not include short-term, easy
fixes but substantial research and development to
find safer production processes that use clean
technologies.
Another Coalition effort involves the Cam-
paign for Responsible Technology, started by
labor, environmental and local public interest
groups, and computer professionals all around
the country who are focusing on problems at
SEMATECH, the research consortium based in
Austin, Texas. We are asking this consortium of
the 14 largest semiconductor companies to
develop safer production technologies in partner-
ship with the federal government because we
realize that individual companies cannot do this
kind of research economically. The progress being
made at the consortium is impressive, not only in
terms of CFC reductions but also in ways to move
away from using toxic gases in semiconductor
processing.
86
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Conclusions
The TRI has been useful in dramatizing toxic
emissions and encouraging reductions. However,
pollutants don't respect boundaries. Multination-
al and transnational companies also want
uniform reporting. With standard regulations and
requirements, companies are less likely to play
different jurisdictions off against each other.
This approach to reductions is often largely
voluntary and nonregulatory. Although 85,000
companies report, EPA does not have 85,000 in-
spectors to verify the data, so enforcement is pret-
ty spotty. That's where some of the non-
governmental organizations come into play — to
enforce compliance through citizen action.
The Silicon Valley Toxics Coalition, as well as
a number of other U.S. groups, has been trying to
negotiate good neighbor agreements with com-
panies that are major polluters in our neighbor-
' T. SMITH
hoods to get them to meet goals in reductions and
also allow citizen inspection.
Lastly, it is important to make the distinction
between waste reduction and decreasing toxics
use. Increasingly, the United States and some
countries in Europe are looking at the product it-
self — distinguishing between waste and toxic
chemical production and use. Many of the chemi-
cal companies are making great progress in
reducing waste, but often the product they make
is toxic.
Our focus on the electronics industry has
been to help it wean itself away from toxic
products. That's why IBM's switch from CFCs to
nontoxic soap and water is such an important ex-
ample.
If we can begin to round off the tremendous
increase in the production of synthetic organic
chemicals, we will see the light at the end of the
tunnel.
87
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Closing Plenary
I
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Closing Plenary: Implications of Toxics
Release Reporting for Other Countries
MODERATOR: Richard P. Wells
Abt Associates Inc.
Cambridge, Massachusetts
Shinlchi Aral
Organization for Economic Cooperation and Development
France
Andrew Lees
Friends of the Earth
United Kingdom
Hans-Peter Baars
TNO—Environmental and Energy Research
The Netherlands
Christopher Ian Pickard
IPC Policy Unit, Department of the Environment
United Kingdom
Jack Holland
Commonwealth Department of Arts, Sport, the Environment, Tourism and Territories
Australia
Maria Kazmukova
OUZPZILINA
Czechoslovakia
Rpreservatives from four countries — The
Netherlands, United Kingdom, Australia,
nd Czechoslovakia — and one multina-
tional organization — the Organization for
Economic Cooperation and Development
(OECD) — as well as a spokesperson for the non-
governmental organizations (NGOs) addressed
the final session of the conference. Their com-
ments provided a perspective from non-United
States representatives at the conference on key is-
sues raised by the international application of a
concept similar to TRI and key potential benefits
and obstacles to such a program. In addition,
several countries described experiences with
similar programs. These comments addressed a
number of common themes as well as topics that
were specific to each country represented.
• The first common theme was the need for inter-
national coordination in the development and im-
plementation of national programs modeled on the
TRI. A number of countries already have
programs similar to TRI in place; others are con-
sidering them. During the conference, repre-
sentatives from industry noted that, in the
absence of coordination, a patchwork of inconsis-
91
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Reporting Releases of Toxic Chemicals
tent national programs would create substantial
reporting burdens; users of these data said they
would face potentially insurmountable data com-
patibility problems.
Shinichi Arai, speaking for the OECD, ad-
dressed the theme of coordination of programs.
He noted that an international system would
• focus on a common set of chemicals,
• provide common basic information that
countries could use as a basis for further
cooperation (for example, prioritizing
chemicals and identifying candidates for
international actions, such as the OECD
risk reduction program), and
• encourage the development of national
right-to-know programs.
Mr. Arai also said, however, that a number of
points should be considered when developing an
international system. In particular, he noted that,
while some countries already collect the kind of
data found in TRI, collection systems vary. Some
countries use licensing or permit systems, while
others have safety reporting systems. Countries
also differ in the use they make of these data.
Some countries use risk-based approaches (taking
into account exposure and toxicity), while others
rely exclusively on emissions data. Finally, each
country has different traditions and existing laws
that govern the public's right to know about en-
vironmental releases. In addition, Mr. Arai also
raised the need to address certain more technical
issues — such as a common standard for report-
ing criteria and a harmonized list of chemicals.
Mr. Arai felt the first step in encouraging an
international system is to facilitate the interna-
tional exchange of information received by
OECD. He felt that adoption of TRI by member
countries would make it easier for others to intro-
duce a similar system. Finally, Mr. Arai felt that
the OECD might be the most appropriate or-
ganization to undertake the harmonization work
needed to introduce TRI internationally. Since the
OECD is a consensus organization, general sup-
port from member countries will be needed for
this activity to succeed.
Andrew Lees of Friends of the Earth UK, who
represented the NGOs attending the conference,
also addressed the need for coordination as part
of six points about TRI presented by the NGOs
(Table 1). Mr. Lees called on industry to operate
everywhere to the highest prevailing world
standards of health and safety and environmental
protection and called on industry to extend the
TRI approach beyond the United States. He ar-
gued that consistent standards are important be-
cause "there is little point... in having a perfectly
green developed world if all the hazardous tech-
nology-is merely exported to the potentially new
markets of the developing world."
Table 1.—Six points presented by NGOs to the Inter-
national Conference on Reporting Releases of Toxic
Chemicals.
1. A public right to know is a fundamental attribute of
democracy.
2. The environment belongs to us all, and everyone has
a right to know about the sources (potential and
actual), nature and impacts of industrial hazards, and
pollution.
3. Industry should be required to operate everywhere to
the highest prevailing world standards of health and
safety and environmental protection.
4. Transnational industrial companies (TNCs) should be
required to provide regulatory bodies and, through
them, the public with TRI-equivalent data for all of
their faculties worldwide. Such TNCs should be seen
to set an example in good neighbor relations.
5. The legislative and other actions indicated above
should be actively supported by both the U.S.
Environmental Protection Agency and the
Commission of the European Communities as well
as governments.
6. The TRI methodology should be extended to
encompass the full range of industrial operations that
affect the environment.
Mr. Lees also argued that transnational com-
panies that collect management information for
the TRI on U.S. operations should report these
data for their non-US operations as well. These
transnationals, he stated, "should play a leader-
ship role and release the information inde-
pendently of the degree of enlightenment of
governments and the cultural perspective of
regulators. If industry truly wants to prove world
leadership when it comes to environmental
protection, we throw down this gauntlet: make
the TRI equivalent data available for all your
operating sites wherever they are."
In his final two points, Mr. Lees called for
concerted international support for the adoption
of a TRI-equivalent system. He also proposed that
the Commission of the European Community
support adoption of a TRI and called for the ex-
tension of TRI methodology "to encompass the
full range of industrial operations that impact on
the environment."
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CLOSING PLENARY
Hans-Peter Baars of the Netherlands Or-
ganization for Applied Scientific Research,
Toegepast Natuurwetenschappelyk Onderzoek
(TNO), described the Dutch emissions registra-
tion system and compared it to TRI by illustrating
the key differences between the two (Table 2). The
Dutch system has both a collective and an in-
dividual component. The collective component
applies to smaller industrial facilities that would
not meet reporting thresholds under TRI and to
certain non-industrial activities, such as emis-
sions from traffic, shipping, households, sewage
treatment, and agriculture. Emissions estimates
for these activities are based on volumes of ac-
tivity and emissions factors. The individual com-
ponent applies to specific facilities with 10 or
more employees and is based on specific calcula-
tions.
Table 2.—Comparison of the United States' TRI and
the Netherlands' reporting system.
U.S. TOXICS RELEASE
INVENTORY
Toxic chemicals (320)
Air/water/soil/off-site
Facility totals
Yearly totals
Every year
Releases
Estimation by company
Selected activities
Selection >25,000 U.S.
Enforced by law
Right-to-Know
DUTCH EMISSIONS
REGISTRATION SYSTEM
All substances (700)
Air/water
Detailed
Emission periods
Every other year
Emissions
By TNO & company
All activities
Weighting system
Voluntary cooperation
Trade secret
Information gathered by the Netherlands'
emissions registration system is generally more
detailed than that gathered by the TRI. Unlike
TRI, which is based on annual facility chemical
release totals, the Dutch system covers individual
units within a facility, such as boilers or cracking
units, and provides data on throughput, pollution
control equipment in place, and the timing of
releases during the year. In addition, the Dutch
system covers all emissions of concern from a
given facility, including acid rain chemicals, such
as sulfur dioxide gases, and chemicals associated
with global warming, such as methane and COa.
The scope of the Dutch emissions registration
system is somewhat narrower than that of the
TRI. When started in 1973, it covered all facilities
with 10 or more employees; the number of
facilities included in the system has, however,
been reduced from 6,300 in 1973 to 700 in 1990.
Data have identified that a smaller number of
companies cause most of the pollution. In addi-
tion, this system covers releases to air and water
only; off-site transfers and solid wastes are not in-
cluded.
Although reporting under the Dutch system
is voluntary, few companies have refused to par-
ticipate. Unlike TRI where emissions are es-
timated by each company, the Dutch government,
through TNO, provides technical assistance to
companies in estimating emissions. Mr. Baars
noted that this approach is important from a
quality assurance viewpoint because it ensures
use of a consistent method at all similar facilities.
However, this approach is resource intensive: the
initial round covering 1973-78 required 500 per-
son-years of labor. By 1990 when the number of
companies in the system had been reduced to 700,
resource requirements had been reduced to 30
person-years.
Christopher Ian Pickard of the United
Kingdom's Integrated Pollution Control Policy
Unit, Department of the Environment, reported
on a system to provide environmental data to the
public that was installed in April 1990. Unlike
those in the United States and the Netherlands,
this system is tied directly to plant operating per-
mits. Plants in the most seriously polluting in-
dustries are required to obtain a permit to operate
those processes. The United Kingdom is now
looking at these industries sector by sector, deter-
mining what constitutes best available techniques
for the industry, deriving limits based on those
techniques, and imposing those limits on in-
dustry. Operators are then required to maintain
the permitted processes and supply monitoring
data to the government, which is now proposing
to aggregate the information annually and make
it available through public registers, along with
detailed data about application and permitting.
Two other speakers described issues facing
countries that are just beginning to consider
making emissions data available to the public.
Jack Holland, from the Commonwealth Depart-
ment of Arts, Sport, the Environment, Tourism
and Territories, outlined initial efforts underway
in Australia, where the government has recently
released a public discussion paper on the
proposed national waste minimization and recy-
cling strategy, which is closely tied to an emis-
sions inventory. Australia also recently
announced it will establish an Environment
93
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Reporting Releases of Toxic Chemicals
Protection Agency. Separating the environment
from the Commonwealth Department of Arts,
Sport, Tourism and Territories will give it much
greater prominence.
No timetable has been set yet for the develop-
ment of an Australian release inventory, and a
number of issues have to be resolved before the
inventory can be fully developed. Chemical con-
trol in Australia is a state matter; the states license
all facilities. The new Australian Environment
Protection Agency will not have the same degree
of authority over state matters as the U.S. En-
vironmental Protection Agency. Unlike Europe
and the United States where environmental
statutes pertaining to chemicals have been in
place for some time, Australia's Chemical
Notification and Assessment Act has been opera-
tive for less than 18 months, and industry is still
absorbing the effects of this act. Mr. Holland was
not sure how industry would handle additional
requirements that followed closely on the Chemi-
cal Assessment and Notification Act; however, he
recognized that multinational businesses with
overseas parent companies are already introduc-
ing these requirements into all operations.
Other issues that must be addressed relate to
types of facilities included in a release inventory.
Australia's chemical industry is based largely on
imports. Recently, a large storage facility went up
in flames, an incident that created a great deal of
public interest in chemical storage and distribu-
tion facilities rather than chemical manufacturing
facilities. Australia needs to determine whether to
confine the release inventory to manufacturing or
to extend it to other industries. In addition,
Australia must look at threshold reporting levels.
Maria Kazmukova described the situation in
Czechoslovakia and other post-Communist
countries:
Many of the things I've heard sound so much
like beautiful poetry and science fiction of the
future, but the problems of my country,
Czechoslovakia, as well as of other post-Com-
munist countries, are quite different. Our
messy political situation as well as an
economic slowdown make people less inter-
ested in environmental problems. For the past
40 years, we have been unable to obtain cor-
rect and full information about our environ-
ment. Technologies that consume too much
energy, a lack of economically based behavior,
missing information and measurements,
together with the absence of not only environ-
mental but even of democratic education —
that is a very sad picture. I would like to ex-
press my hope that this situation will be
soothed step by step.
I think such a situation is dangerous because
people, not only in Czechoslovakia, but in
many other poor countries as well, will not
care about the environment, but simply prefer
to satisfy temporary social needs. That's the
danger, but I hope this situation can be im-
proved. This conference is evidence that the
problem is not only one for the developed
countries; it is also a problem of a global ap-
proach. We all clearly have a common future.
• A question that arose repeatedly in commen-
tary by non-US participants in the conference was
the question of public access to environmental data. In
large measure, the power of TRI derives from the
fact that it is available and readily accessible to
the public. Members of the public with access to
quite common information technology can,
moreover, easily obtain detailed plant- or loca-
tion-specific data. Data availability has made TRI,
in effect, a powerful public report card on
industry's environmental performance, and many
corporate actions to reduce releases can be traced
to this fact. In other countries, the traditions of
public access to environmental data are not as
completely established as in the United States.
Several speakers anticipated that their countries
would resist making release data widely available
to the public.
Shinichi Arai stated that an international TRI
would encourage the development of right-to-
know laws in member countries to ensure public
access to information on chemicals or facilities.
Mr. Arai noted that OECD also has some systems
to facilitate public access to information that may
prove useful to developing a release inventory. In
applying these systems, however, it is important
to recognize that individual countries' situations
differ.
Andrew Lees emphasized that public access
goes beyond making data available:
A right to know is not a right to know if you
know where to look, if you know how to ask a
technical question. A right to know is a civil
or public service ethos among regulators and
administrators that makes it easy for the
public to exercise their right /o know. What
we have seen from the NGO perspective, ex-
emplified by the staff from EPA, is that en-
lightened attitude, that 'how can we help
94
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CLOSING PLENARY
you?'attitude that really empowers the public
in their right to know.
Mr. Lees also argued that:
No one actually owns the environment (from
a philosophical perspective). We all have com-
mon rights in it, but we cannot regard it as a
common whereby we seek to maximize our ex-
ploitation of it before somebody else grabs
their share. We've got to take that common in-
terest perspective on the environment. That
means, in effect, that if somebody wishes in
the service of their own private or corporate
interests to make use of the environment, they
have a responsibility to use it right in a care-
ful, caring way, but they also have a moral
obligation to make public everything that
they're doing. Because the environment is a
public good that is subject to the impact of
their activities. Therefore, we would say you
have no right to claim that you can hide
everything. There may be a justification for
trade secrets to be protected, but again the
EPA rule is good there: a reasoned case must
be made; you have to prove your case. So it
should be a stringent test to have a claim of
commercial confidentiality or trade secret to
protect your interests from public scrutiny.
Hans-Peter Baars noted that the Netherlands'
voluntary system is not available to the public on
a plant-specific basis: "The Community Right-to-
Know Act does not exist in our country yet. We
can only publish aggregated data, and only the
government has access to these detailed data."
Christopher Ian Pickard noted that the
United Kingdom is now proposing to provide
data to the public on authorization permits for
seriously polluting industries. Detailed data con-
cerning both the permits and operator monitoring
of the processes to which the permits apply will
be made available through public registers.
Australia, also, has no tradition or law about
community right to know, according to Jack Hol-
land. Because states and other Commonwealth
departments have considerable influence, Mr.
Holland said, "We will have to examine if such
laws will be enacted. Again, this will require
cooperation from the states and from other Com-
monwealth departments. From what I've heard
this week, the value of a release inventory is very
much diminished if excessive use of trade secrecy
provisions can be made."
In Czechoslovakia and other post-Com-
munist countries, according to Maria Kazmu-
kova, the situation is made even more complex by
the absence of information and measurements
and a democratic tradition. These circumstances
and the economic situation in the post-Com-
munist world are dangerous because "people .. .
will not care about the environment but simply
prefer to satisfy temporary social needs."
• Finally, some of the speakers addressed other
topics that pertain to the relationship between a
release inventory and other aspects of risk manage-
ment.
Shinichi Arai noted that approaches to risk
differ among OECD member countries, with
some countries focusing only on release data
while others couple release data with toxicity and
exposure data to develop risk-based approaches.
Christopher Ian Pickard underlined the
relationship between an inventory and an in-
tegrated pollution control approach. He noted
that, in the United States, TRI had been an im-
petus for the development of an integrated pollu-
tion approach, whereas in Europe an integrated
pollution approach might result in an emissions
inventory.
The OECD has made a ministerial recommen-
dation for an integrated pollution prevention and
control approach. A European Commission direc-
tive is being negotiated for an integrated ap-
proach, and the United Kingdom has recently
started to integrate its approach to pollution
prevention.
Jack Holland reiterated these points:
As we have all heard very strongly and
repeatedly, a release inventory provides many
opportunities for pollution prevention and
source reduction. These two concepts lie at the
heart of our waste minimization and recycling
strategy. We {the United Kingdom] think a
public emissions register is something that
goes along very closely with that.
95
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INTERNATIONAL CONFERENCE ON REPORTING
RELEASES OF Toxic CHEMICALS
November 13-15, 1991 • Vienna, Austria
Sponsored by the
Office of Prevention, Pesticides and Toxic Substances
U.S. Environmental Protection Agency
in conjunction with the
Organization for Economic Cooperation and Development
LIST OF ATTENDEES
Zoltan Adamis
Head of lexicological Information Service
National Institute of Occupational Health
Nagyvarad Ter 2
P.O. Box 22
H-1096 Budapest Hungary
TEL 36.1.1137.890
Shinichi Aral
Iministrator, Chemicals Division,
Environment Directorate
Sanization for Economic Cooperation
and Development
2, rue Andre Pascal
F-75775 Paris Cedex 16 France
TEU 33.1.4524.7907
FAX: 33.1.4524.1675
Hans-Peter Baars
TNO - Environmental and Energy Research
P.O. Box6011
NL-2600JA Delft The Netherlands
TEL 31.15.696.6019
FAX: 31.15.61.68.12
Alastair D. Baillie
Institute for European Environmental Policy
158 Buckingham Palace Road
London SWIW 9TR United Kingdom
TEL 44.71.824.8787
FAX: 44.71.824.8145
Arpad Bakonyi
Head of Department, Ministrial Commission
Ministry of Industry & Trade
I Martirok Utja 85
H-1525 Budapest Hungary
TEL 36.1.175.4528
FAX: 36.1.175.0219
Geoff N. Barlow
European Environmental Manager
Rohm and Haas
Ellison Street
Jarrow
me & Wear NE32 3DJ United Kingdom
Vj 44.91.483.8888
^AX: 44.91.428.0255
Earl R. Beaver
Technology Director, Waste Elimination
Monsanto Company
800 N. Lindbergh Blvd.
Mail Code: F2WJ
St. Louis, MO 63167 U.S.A.
TEL 314.694.6087
FAX: 314.694.6138
Ben Beckers
General Manager
Lisec Environmental Research &
Consulting
Craenevenne 140
B-3600Genk Belgium
TEL 32.011.36.27.91
FAX: 32.011.35.58.05
Hakan Bjomdal
Swedish Environmental Protection Agency
S-171 85Solna Sweden
TEL 46.8.799.1177
FAX: 46.8.989.902
Jos Bormans
Advisor to the Secretary of State on
Environment
Elizabethan 208B03
B-8301 Knokke-Heist Belgium
TEL 32.50.615.256
FAX: 32.50.615.216
Steve Buchanan
Unisys Corporation
79 Alexander Drive
2nd Floor
Research Triangle Park, NC 27711 U.S.A.
TEL 919.541.3923
Andrew Campbell
Environment, Nuclear Safety and Civil
Protection (DG XI)
Commission of the European Communities
34, Rue Befliard
B-1049 Brussels Belgium
TEL 32.2.2356.5560
FAX: 32.2.2350.144
97
Lisa Marie Capozzoli
TRI User Support Librarian
Labat-Anderson
c/o U.S. Environmental Protection Agency
401 M Street, S.W. (TS-793)
Washington, DC 20460 U.S.A.
TEL 202.260.0568
FAX: 202.260.4655
Margot Cella
Abt Associates Inc.
4800 Montgomery Lane
Suite 500
Bethesda, MD 20814 U.S.A.
TEL 301.913.0500
FAX: 301.652.7530
M. Chaugny
Environment, Nudear Safety, and Civil
Protection (DG XI)
Commission of the European Communities
200 rue de la Loi
DG XI/A2 - B34/5-9
B-1049 Brussels Belgium
TEL 32.2.235.98.08
FAX: 32.2.235.974
John Coffey
Depurty Chief Engineering Advisor
Department of the Environment
Customs House
Dublin 1 Ireland
TEL 01.679.3377, Ext. 2609
FAX: 01.742.423
Robert Costa
ICF, Inc.
9300 Lee Highway
Fairfax, VA 22031 U.S.A.
Peter Czedik-Eysenberg
Dr. Hon Univ Prof Wissenschaftliche
Abteilung
Osterreichische Unilever GmbH
Scenkenstrasse 8
Postfach 71
A-1011 Vienna Austria
TEL 43.222.531.19.239
FAX: 43.222.535.12.73
-------
Denise Devoe
Director, Washington Operations
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
401 M Street, S.W. (ANR-443)
Washington, DC 20460 U.S.A.
TEL 202.260.5575
FAX: 202.260.0451
Rupert Fellinger
Osterreichisches Okologie Institut
Seidengasse 13
A-1070 Vienna Austria
TEL 43.222.9361.0522
FAX: 43.222.523.5843
Roland Fendler
Dipl. Ing.
Oko - Institut e.V.
Buro Darmstadt
BunsenstraSe 14
D-6100 Darmstadt Germany
TEL 49.6151.81.91.25
FAX: 49.6151.81.91.33
Brad Firlie
Abt Associates Inc.
4800 Montgomery Lane
Suite 500
Bethesda, MD 20814 U.S.A.
TEL: 301.913.0500
FAX: 301.652.7530
Elizabeth A. Fisher
Environmental Manager
Rohm and Haas Company
Sixth and Market
Independence Mall West
Philadelphia, PA 19105 U.S.A.
TEL: 215.592.2545
FAX: 215.592.6761
Maria Furhacker
Dipl. Ing.
Universitat fur Bodenkultur Wien
Nussdorfer Lande 11
A-1190 Vienna Austria
TEL: 43.222.36.92.924.755
FAX: 43.222.36.92.924.200
Dag B. Granbakken
Senior Executive Officer
State Pollution Control Authority
P.O. Box8100Dep.
N-0032 Oslo Norway
TEL 47.2.573.452
FAX: 47.2.676.706
Jan-Arvid Gravklev
Senior Scientist
Norsk Hydro
Research Centre
P.O. Box 2560
N-3901 Porsgrunn Norway
TEL 47.3.563.871
FAX: 47.3.562.733
Attila Hajdu
Senior Advisor
Ministry of Industry and Trade
Department for Environmental
Management
H-1525 Budapest Hungary
TEL 36.1.15.58.363
Loren H. Hall
Chief, Risk Guidance Development Staff
U.S. Environmental Protection Agency
Existing Chemical Assessment Division
Office of Pollution Prevention and Toxics
(TS-798)
401 M Street, S.W.
Washington, D.C. 20460 U.S.A.
TEL 202.260.3931
FAX: 202.260.8168
Gary Hamilton
GIS Analyst
ViGYAN, Inc.
5203 Leesburg Pike
Suite 900
Falls Church, VA 22041 U.S.A.
TEL 703.931.1100
FAX: 703.820.4332
Eva Hellsten
Senior Scientific Officer
National Chemicals Inspectorate
P.O. Box 1384
S-171 27Solna Sweden
TEL: 46.8.730.6792
FAX: 46.8.735.7698
Thomas Hellstrom
Swedish Water and Waste Water Works
Association
Regeringsgatan 86
S-111 39 Stockholm Sweden
TEL 46.8.23.28.35
FAX: 46.8.21.37.51
Paul Hill
President
National Institute for Chemical Studies
2300 MacCorkle Avenue, S.E.
Charleston, WV 25304 U.S.A.
TEL: 304.346.6264
FAX: 304.346.6349
Alex Hittle
Friends of the Earth — U.S.
218 D Street, S.E.
Washington, D.C. 20003 U.S.A.
TEL 202.544.2600
FAX: 202.543.4710
Jack Holland
Acting Director
Chemicals Assessment Section
Commonwealth Department of the Arts,
Sport, the Environment, Tourism and
Territories
GPO Box 787
Canberra, Act, 2611 Australia
TEL: 616.274.1477
FAX: 616.274.1123
Lars Holm
Civil Engineer
Fyns Ami
Department of Technology and
Environment
Oerbaekvej 100
DK-5220 Odense S- Denmark
TEL: 45.66.159.400
FAX: 45.66.154.559
Roszell D. Hunter
Associate
Hunton & Williams
106 Avenue Louise
B-1050 Brussels Belgium
TEL 32.2.646.0010
FAX: 32.2.646.0246
Peter Hurst
Chemicals and Consumer Policy Officer
WWF International
Ave. du Mont-Blanc
CH-1196 Gland Switzerland
TEL 41.22.64.95.27
FAX: 41.22.64.82.19
Wilfrid Jan
Project Engineer
Environment Canada
18th Floor, PVM
351 St. Joseph Blvd.
Hull, Quebec K1AOC8 Canada
TEL 819.994.3149
FAX: 819.953.9542
Bo Jansson
Swedish Environmental Protection Agency
Special Analytical Lab
S-171 85Solna Sweden
TEL 46.8.799.1463
FAX: 46.8.287.829
Jorn Hesselluno Jeppesen
Civil Engineer
Fyns Amt
Department of Technology and
Environment
Oerbaekvej 100
DK-5220 Odense S- Denmark
TEL 45.66.159.400
FAX: 45.66.154.559
Zdena Jurcikova
Engineer
Water Research Institute
Nabr. Svobodu 5
CS-812 49 Bratislava Czechoslovakia
TEL 42.7.315.744
FAX: 42.7.315.743
Sandor Kantor
Chemical Engineer Expert
Green Future Association
Sennelouels u. 23
H-1052 Budapest Hungary
TEL 36.1.1379.618
FAX: 36.1.181.2755
Maria Kazmukova
OUZP ZILINA
Kubinska 10
CS-01008Zilina Czechoslovakia
TEL 42.89.22619
FAX: 42.89.20825
Istvan Kiss
Scientific Director
Toxicological Research Centre Ltd.
H-8200 Veszprem Hungary
TEL 36.80.21.509
98
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Pirkko Kivela-lkonen
Vistry of the Environment
. Box 399
Helsinki Finland
TEL 358.0.1991.264
FAX: 358.0.1991.617
Jozsef Kovacs
Geschafuhrer
REKO Umweltschutz GmbH Ungam
7604 Pecs, Budai N.A.u.L.
H-7604Pecs Hungary
TEL 36.72.14.767
FAX: 36.72.14.767
Peter Kulnigg
Oatamed GmbH
Ameisgasse 49
A-1140 Vienna Austria
TEL 43.1.94.56.46
FAX: 43.1.94.56.46.99
Robert Kumplent
Unisys Corporation
79 Alexander Drive
2nd Floor
Research Triangle Park, NO 27711 U.S.A.
TEL 919.541.3923
Beatrice Labarthe
Consultant
International Register of Potentially Toxic
Chemicals
United Nations Environment Programme
Palais des Nations
CH-1211 Geneva 10 Switzerland
|EL 41.22.988.400
•X: 41.22.733.2673
Arno W. Lange
Director and Professor
Federal Environmental Agency
Bismarkplatz 1
D-1000 Berlin 33 Germany
TEL 43.30.8903.2551
FAX: 43.30.8903.2285
Carl J. Larsen
Director, Environmental Operations
Monsanto Services International SA/NV
Ave. de Tervuren 270-272
B-1150 Brussels Belgium
TEL 02.761.49.98
FAX: 02.761.40.40
Andrew Lees
Campaigns Director
Friends of the Earth
26-28 Underwood Street
London N17 JQ United Kingdom
TEL 44.71.490.1925
FAX: 44.71.251.0818
Barbara Lubkert-Alcamo
Consultant
Commission of the European Communities
45 Av. O'Auderghem
B-1040 Brussels Belgium
TEL 32.2.235.77.63
FAX: 32.2.236.43.39
Alf. G. Lundgren
National Chemicals Inspectorate
P.O. Box 1384
S-171 27Solna Sweden
TEL 46.8.730.6742
FAX: 46.8.735.7698
Susanne Moller
Master of Science
National Agency of Environmental
Protection
Strandgade 29
DK-1401 Copenhagen Denmark
TEL 45.31.57.83.10
FAX: 45.31.57.2449
lain MacLean
Chief Environmental Officer
Cork County Council
Cork Ireland
TEL 353.21.276.891
FAX: 353.21.276.321
Gatta Mario
Ecology Manager
Montecatini SpA
Foro Buonaparte 31
1-20121 Milan Italy
TEL 39.2.6270.5346
FAX: 39.2.6270.5345
John D. Marshall
Her Majesty's Inspectorate of Pollution
Romney House
Marsham Street
London SW1P SPY United Kingdom
TEL 44.71.276.8584
FAX: 44.71.276.8562
Attila F. Marton
Chemical Engineer
Ministry for Environmental and Regional
Policy
Department of Waste Mangement
P.O. Box 351
H-1394 Budapest Hungary
TEL 36.1.201.24.91
FAX: 36.2.201.24.91
Agneta Melin
Senior Technical Officer
Swedish Environmental Protection Agency
Statens Naturvardsverk
S-171 85 Solna Sweden
TEL 46.8.799.1168
FAX: 46.8.98.9902
Kadas Miklos
Engineer
REKO Umweltschutz GmbH Ungarn
7604 Pecs, Budai N.A.u.L.
H-7604 Pecs Hungary
TEL 36.72.14.767
FAX: 36.72.14.767
Regine Moevius
Pesticide Action Network (PAN) FRG
Kleingemunderstrasse 27 A
D-6900 Heidelberg
TEL 49.06221.80.48.78
Antonin Mucha
Specialist
Czech Ministry of Environment
Vrsovicka 65
CS-101 10 Prague 10 Czechoslovakia
TEL 42.02.742.341
FAX: 42.02.731.357
Warren R. Muir
President
Hampshire Research
9426 Forest Haven Drive
Alexandria, Virginia 22309 U.S.A.
TEL 703.780.7474
FAX: 703.684.7704
Masahiro Nakadate
Chief, Division of Risk Assessment
National Institute of Hygienic Sciences
1-18-1 Kamiyoga
Setagaya-ku
Tokyo 158 Japan
TEL 81.3.3700.1141
FAX: 81.3.3707.6950
Steven Newburg-Rinn
Chief, Public Data Branch
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
(TS-793)
401 M Street, S.W.
Washington, D.C. 20460 U.S.A.
TEL 202.260.3757
FAX: 202.260.4655
Dagmar Oertel
Dipl.-Chem.
Institute for Industrial Protection
Universitat Karlsruhe
HertzstraBe16
D-7500 Karlsruhe 21 Germany
TEL: 49.721.608.4584
FAX: 49.721.75.89.09
Robin R. Ollis
Technical Director
National Institute for Chemical Studies
2300 MacCorkle Avenue, S.E.
Charleston, WV 25304 U.S.A.
TEL 304.346.6264
FAX: 304.346.6349
Robert G. Palmer
Environmental Scientist
General Sciences Corporation
6100 Chevy Chase Drive
Laurel, MD 20707
TEL 301.953.2700
FAX: 301.953.1213
Eszter Paszto
Expert on International Environmental
Affairs
Ministry of Industry & Trade
I Martirok 85
P.O. Box 96
H-1525 Budapest Hungary
TEL 36.1.175.4528
FAX: 36.1.175.0219
99
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Zsuzsanna Pataki
Head of Section
Superintendent for Chemical and
Explosives Industry
Serleg u. 9
H-1118 Budapest Hungary
TEL 36.1.18.50.228
Lena Perenius
Principal Technical Officer
National Chemicals Inspectorate
Box 1384
S-171 27Solna Sweden
TEL 46.8.730.5700
FAX: 46.8.735.7698
Ales Petrovic
Institute of Public Health
Trubarjeva 2
YU-61000 Ljubljana, Slovenia Yugoslavia
TEL 38.61.123.245
FAX: 38.61.323.955
Christopher Ian Pickard
IPC Policy Unit
Department of the Environment
Room A111, Romney House
43 Marsham Street
London SW1P SPY United Kingdom
TEL 44.71.276.8916
FAX: 44.71.276.8600
Jerry Poje
Green Seal
1875 Connecticut Ave., N.W.
Suite 300-A
Washington, D.C. 20009 U.S.A.
TEL 202.986.0520
FAX: 202.328.8087
Gordon Pope
Special Advisor, National Pollutant
Release Inventory
Environment Canada
18th Floor
Place Vincent Massey
Hull, Quebec K1AOH3 Canada
TEL 819.953.1654
FAX: 819.953.9542
Otto Rente
Dipl.-Chem.
Institute for Industrial Protection
Universitat Karlsruhe
HertzstraSe16
D-7500 Karlsruhe 21 Germany
TEL 49.721.608.4460
FAX: 49.721.75.89.09
Ulf Rick
Head, Product Register
National Chemicals Inspectorate
Box1384
S-171 27Solna Sweden
TEL 46.8.730.5700
FAX: 46.8.735.7698
Philip D. Roberts
Group Environment Advisor
ICI Chemicals & Polymers Ltd.
P.O. Box 13, The Heath
Runcorn, Cheshire WA7 4QF United
Kingdom
TEL 44.928.511.271
FAX: 44.928.581.204
David Sarokin
Environmental Protection Specialist
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
(TS-792A)
401 M Street, S.W.
Washington, O.C. 20460 U.SA
TEL 202.260.6396
011.4471.253.4991
Sam K. Sasnett
Director, TRI Management Staff
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
(TS-779)
401 M Street, S.W.
Washington, D.C. 20460 U.S.A.
TEL 202.260.1821
FAX: 202.260.0981
Louis Schnurrenberger
F. Hoffman - La Roche AG
Abt. CSE, Bau 49/240
Postfach
CH-4002 Basel Switzerland
TEL 41.61.688.66.38
FAX: 41.61.688.15.79
Jyri Seppala
MSc
National Board of Waters and the
Environment
Urho Kekkosenkatu 4-6 E
00100 Helsinki Finland
FAX: 358.0.695.1326
Russel G. Shearer
Environmental Physical Scientist
Federal Government of Canada
Department of Indian and Northern Affairs
10 Wellington Street
6th Floor
Ottawa, Ontario K1AOH4 Canada
TEL 819.994.7484
FAX: 819.994.6419
Ted Smith
Silicon Valley Toxics Coalition
760 North First Street
San Jose, CA 95112 U.S.A.
TEL 408.287.6707
Margareta Stackerud
Principal Technical Officer
Swedish Environmental Protection Agency
S-171 85 Solna Sweden
TEL 46.8.799.1618
FAX: 46.8.989.902
Urs Staempfli
Federal Office of Environment
Hallwylstrasse 4
CH-3003 Bern Switzerland
TEL 41.31.61.69.62
FAX: 41.31.61.79.81
Dorothy A. Stroup
TOXNET/TRI Specialist
National Library of Medicine
8600 Rockville Pike
Building 38A
Room 3S-320
Bethesda, MD 20894 U.S.A.
TEL 301.496.6532
FAX: 301.450.3537
100
Judith Sutterfield
Conference Coordinator
JT&A, inc.
1000 Connecticut Ave., N.W.
Suite 802
Washington, D.C. 20036 U.S.A.
TEL 202.833.3380
FAX: 202.466.8554
Gabor Szabo
Deputy State Secretary
Ministry for Environmental & Regional
Policy
I.Fo utca 44-50
P.O. Box 351
H-1394 Budapest Hungary
TEL 36.1.201.37.64
FAX: 36.1.201.28.46
Carlene Taggart
Manager
JT&A, inc.
1000 Connecticut Ave.. N.W.
Suite 802
Washington, D.C. 20036 U.S.A.
TEL 202.833.3380
FAX: 202.466.8554
Linda A. Travers
Director, Information Management Division
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
(TS-793)
401 M Street, S.W.
Washington, D.C. 20460 U.SA
TEL 202.260.3938
FAX: 202.260.1657
David J. Trouba
Conference Coordinator
JT&A, inc.
1000 Connecticut Ave., N.W.
Suite 802
Washington, D.C. 20036 U.S.A.
TEL 202.833.3380
FAX: 202.466.8554
Ivan Vallo
Chemical Engineer
Ministry for Environmental and Regional
Policy
Department of Waste Mangement
P.O. Box 351
H-1394 Budapest Hungary
TEL 36.1.201.24.91
FAX: 36.2.201.24.91
Bruno M. Vasta
TOXNET Administrator
National Library of Medicine
8600 Rockville Pike
Building 38A
Room 3S-320
Bethesda, MD 20894 U.S.A.
TEL 301.496.6531
FAX: 301.480.3537
Kristina Voigt
GSF/PUC
IngolstSdter LandstraBe 1
D-8042 Neuberberg Germany
TEL 89.3187.2953
FAX: 89.3187.3449 i
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Andrew Wadge
Department of Health
1901 Hannibal House
bphant & Castle
don SE1 6TE United Kingdom
TEL 44.71.972.2147
FAX: 71.703.9565
Bud Ward
Executive Director
Environmental Health Center
National Safety Council
1050 17th Street, N.W.
Suite 770 Washington, D.C. 20036
USA.
TEL 202.293.2270
Mary Ellen Weber
Director, Economics and Technology
Division
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
(TS-779)
401 M Street, S.W.
Washington, D.C. 20460 U.S.A.
TEL 202.260.0667
FAX: 202.260.0981
Erich Weber
Der Bundesminister fur Umwett,
Naturschutz und Reaktorsicherheit
Postfach 12 06 29
D-5300 Bonn 1 Germany
TEL 49.228.305.2421
FAX: 49.228.305.3524
Richard Wells
Abt Associates Inc.
55 Wheeler Street
Cambridge, MA 02138-1168 U.S.A.
TEL 617.492.7100
Robert Wevodau
Principal Consultant, Air Quality Group
Dupont Company
1353 Loueiers Building
Engineering Department
P.O. Box 6090
Newark, DE 19714-6090 U.S.A.
TEL 302.366.3748
FAX: 302.366.2057
Gill Witter
Pollution Policy Officer
World Wide Fund For Nature
Panda House
Weyside Park
Catteshall Lane
Godalming, Surrey GU71XR United
Kingdom
TEL 44.483.412.501
FAX: 44.483.426.409
Chris Yarnell
Deputy Director, Environment Unit
Department of Trade and Industry
151 Buckingham Palace Road
London SW1W9SS United Kingdom
TEL 44.71.215.1015
FAX: 44.71.215.2909
101
•{rU.S. Government Printing Office : 1992 - 312-014/40107
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