U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF PESTICIDES AND TOXIC SUBSTANCES 401 M STREET S.W. WASHINGTON, DC 20460 TOXIC CHEMICAL RELEASE INVENTORY (TRI) STATE DATA ENTRY FEASIBILITY ANALYSIS FEASIBILITY ANALYSIS FINAL CONTRACT #68-W9-0037 DELIVERY ORDER #112 August 5, 1992 BOOZ'ALLEN & HAMILTON Inc. 4330 East West Highway Bethesda, Maryland 20814-44-55 301/951-2200 ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF August 19, 1992 -T.C.D.. ANO TOX.C Dear Chemical Information Management Project Members: Enclosed are copies of the Interview Summary and Final Report for the Toxic Release Inventory State Data Entry Feasibility Analysis, as promised at the last FOSTTA meeting. The Report was prepared by the contractor Booz*Allen & Hamilton. Included in the Interview Summary is a list of those people who were interviewed for the Report. I would like to thank the FOSTTA Project for meeting with the contractor during the last two meetings and especially thank those members of FOSTTA who agreed to be interviewed. The Final Report is undergoing Agency review and no decisions have been made based on the options or recommendations. If you have any questions about the Report, please contact me at (202) 260-3757. Sincerely, Steven Newburg-Rinn, Chief Public Data Branch enclosures ------- TABLE OF CONTENTS EXECUTIVE SUMMARY iii Chapter 1 INTRODUCTION 1 Background 1 Purpose and Approach 4 Chapter 2 CHARACTERISTICS OF EXISTING DATA BASES USING STATE DATA ENTRY APPROACH 7 BRS 7 AIRS 11 Conclusions 14 Chapter 3 STATE AND REGIONAL INTERVIEWS 17 State Interviews 17 Regional Interviews 20 Chapter 4 DEFINITION OF CRITERIA FOR FEASIBILITY 23 Legislative Requirements 23 User Requirements 24 Operational Requirements 27 Fatal Criteria 28 Chapter 5 DEFINITION OF ALTERNATIVE APPROACHES 31 Status Quo 31 State-Based 32 State-Entry with Centralized Data Quality/Normalization 33 Hybrid 34 Chapter 6 ANALYSES OF OPTIONS AND RECOMMENDATIONS 37 Criteria Failing to Meet Fatal Factors 37 Analysis of Remaining Options 39 Recommendations 48 Conclusion 51 Feasibility Analysis ------- Table of Contents Appendix A INTERVIEWEE LIST 53 Appendix B INTERVIEW GUIDES 57 Appendix C STATE INTERVIEW MATRIX 67 Appendix D COST ANALYSIS ASSUMPTIONS 69 Feasibility Analysis ii ------- EXECUTIVE SUMMARY Background In 1987 the Toxics Release Inventory (TRI) was established to meet the public's demand for information about toxic chemicals in their community. The law requires that EPA make this inventory available and accessible to the public in various formats, but specifically in the form of a computer data base. Since the creation of the TRI program, the public has become more aware of the presence and effects of toxic chemicals, and has effectively used TRI data to promote emergency planning, pollution prevention, waste minimization, and other activities. Due to the usefulness of TRI data and the success of the TRI program, the public's desire to know more about toxic chemicals continually grows. In response to this demand, TRI has been expanded by EPA and Congress to incorporate the need for access to additional information. Purpose and Approach Because of the increased volume of data to be processed by TRI and the demands from users to have access to the data more quickly than the current time frame, EPA is considering alternative data entry and management approaches. Because several states have indicated interest in performing TRI data entry at the state level, EPA has requested a study to determine the feasibility of state data entry for TRI through an examination of: The benefits, costs, and management issues raised by decentralized TRI data management approaches The logistical activities which would need to take place for such an approach to succeed. In order to obtain the information necessary to evaluate the feasibility of moving to a system based solely or partially on entry of data at the state level, a series of interviews were conducted with: EPA Headquarters and Regional personnel involved with TRI State personnel involved with TRI System managers, state, and Regional personnel involved with two other EPA data bases using a state data entry approach. Feasibility Analysis Hi ------- Executive Summary This data collection was based on structured interview guides that were administered through face-to-face and telephone interviews. A list of interviewees is included in Appendix A of this document and copies of the interview guides in Appendix B. BRS and AIRS Summary The Biennial Reporting System (BRS) and the Aerometric Information Retrieval System (AIRS), two data bases that rely upon data entry at the state level, were examined to determine the benefits and problems associated with this type of data management system. Although these two systems are not identical to TRI, they do serve as useful tools for evaluating the feasibility of state data entry for TRI. One important difference between these two systems and TRI is that these systems support programs that are state delegated, and states are primary users of the data. TRI, however, is not a state delegated program, and does not possess the more formal state, Regional, and Headquarters relationships upon which these two systems depend. An obvious benefit of state data entry for both BRS and AIRS is that the states are more knowledgeable about the facilities than EPA staff, and recognize and resolve problems with the data more quickly. Data entry is also accomplished more quickly by the individual states if they are active participants, rather than by a centralized system entering all the data. However, if a significant number of states do not participate in the data entry process, this requires additional time and resources for EPA to enter the data for the state. Coordinating with the states is clearly a challenge with both systems. Additional time and resources are required in data conversion if states perform data entry, and do not utilize the appropriate conversion software or experience other problems with conversion. All states do not always adhere to the coding conventions and standards for data entry/ and consequently data quality suffers. Data quality is also affected when states do not have sufficient resources to adequately perform data quality checks. As can be seen, there are benefits to performing data entry at the state level, but there are also significant challenges. Although the problems associated with this approach may not severely affect the overall performance of these two systems, it is necessary to evaluate the unique requirements of TRI to determine the feasibility of this approach for TRI. State and Regional Interview Summary Both the states and the Regions saw potential benefits of the state data entry approach, including higher data accuracy, improved timeliness, and an Feasibility Analysis iv ------- Executive Summary increased sense of ownership, interest, and usage of TRI data by the states. But state and Regional interviewees indicated that the extent to which the benefits would be realized depended upon many factors. One major factor included the ongoing commitment from states in participating. States currently have a wide variety of capabilities, interests, and usages of TRI data.1 Therefore, all states may not be interested in, and committed to, performing data entry for the long term. Other states may be interested primarily in fulfilling their needs and not the broader requirements of a national database. State and Regional interviews indicated that for decentralization to work effectively, state commitment is a necessity. Other factors impacting the success of a state data entry approach included the availability of resources and the resolution of many logistical activities that must take place. All states have varying levels of capabilities and available resources, therefore in most cases funds would need to be allocated by EPA toward ensuring the states have the appropriate hardware, software, and training to perform data entry. Logistical issues that would need to be resolved include quality assurance/quality control, data normalization and standardization, the processing and assignment of document control numbers to Form Rs, and the revisions to data not only for the current year, but also for previous years. States and Regions indicated that these factors must be sufficiently addressed before decentralization is considered feasible. States strongly emphasized that they would need to participate actively in resolving these issues to ensure that their needs are met as well as national needs. Interviewees felt that Regional offices should act primarily in an assistance role, not an operational role. This could involve acting as a liaison between the states and Headquarters and acting as the administrator of any grants. Feasibility Criteria To assess the feasibility of moving from centralized data entry to a successful state-based approach, criteria for the assessment were defined. These criteria were based upon the assessment of the other systems using state data entry approaches as well as an in-depth understanding of the unique requirements and needs of the TRI program and of state capabilities and interests. These criteria fall into three main categories: Legislative Requirements Data base is national in scope* 1 A matrix in Appendix C summarizes the capabilities and interests of states interviewed for this analysis. * The criteria followed by an asterick are considered to be "fatal" criteria. v Feasibility Analysis ------- Executive Summary TRI supports legislatively mandated uses* Publicly accessible on-line* Required data elements are present in the data base* User Requirements Accuracy close to 100% in critical data elements, such as release fields, and very high in all others Data sufficiently standardized across the data base to facilitate searching Data are available within six months Both the data and the forms are available on an ongoing basis Operational Requirements Alternative can be implemented within projected resources All participants in the alternative are committed* Data ownership issues do not negatively affect the ability to compile the national data base Significant increases in reporting requirements can be handled by the alternative* There are six criteria considered to be "fatal" criteria. All legislative requirements are considered to be fatal because failure to meet any of the requirements would keep EPA from meeting its legal obligations. Participant interest is considered fatal because if any participant required by an approach is not committed, then implementation of that approach will not be. feasible. The ability to expand to handle increased reporting requirements is also considered fatal because the likelihood that TRI reporting requirements will be expanded over the next five years is very high. If any of the alternative approaches cannot be expanded, then this approach will not be feasible over time. Therefore, it is not efficient to implement a new approach for the very short term. Alternative Approaches Four alternative approaches were defined and analyzed against the criteria. These alternatives include: Feasibility Analysis vi ------- Executive Summary Centralized (Status Quo) - the current system where EPA receives forms from industry, enters data, performs all quality assurance (i.e., identifies both data entry and reporter errors), and makes the data available to the public. This alternative also assumes the potential addition, in the short-term, of image processing and/or optical character recognition (OCR) technologies. State-Based - all states would be responsible for all activities that EPA performs in the status quo. The states would then upload the data to EPA's mainframe; no additional data quality checks would be done on the national data base State Entry with Centralized Quality Assurance - all states would be responsible for entering and verifying data entry accuracy. EPA would perform additional quality assurance checks on the data to ensure standardization of the data and to identify reporter errors. Hybrid - interested states would perform data entry and verification, and EPA would do data entry and verification for the remaining states. EPA would also be responsible for all quality assurance on the national data base as in the previous alternative. These alternatives were then evaluated relative to the feasibility criteria. Evaluation Each alternative was first evaluated relative to the fatal criteria to determine if the alternative would allow legal requirements to be met and if it was implementable. At this point in the analysis, no attempt was made to determine which alternative best satisfied each criterion. Rather, each alternative was evaluated to see if it satisfied a fatal criterion to any degree. This analysis is summarized in the graphic on the following page. vii Feasibility Analysis ------- Executive Summary Exhibit i-1 Status Quo State-Based State Entry with Centralized Quality Assurance Hybrid - indicates that alternative satisfies fatal criterion Two alternatives - state-based and state entry with centralized quality assurance - were eliminated because both of these alternatives do not satisfy three critical fatal criteria. The two remaining alternatives - status quo and hybrid - were assessed against the 12 established criteria. These alternatives received one of three ratings relative to each criterion: Does not meet the criterion Moderately satisfies the criterion Fully satisfies the criterion. This analysis is summarized in the chart on the following page. Feasibility Analysis vin ------- Executive Summary Exhibit i-2 Jj Does not satisfy criterion Moderately satisfies criterion Fully satisfies criterion Because of the ability of the status quo approach to fully satisfy over 80% of the criteria, it clearly remains a strong approach. The hybrid approach is almost split evenly between criteria that it fully satisfies and those that it moderately satisfies. Recommendations Both of the two alternatives that satisfied all of the fatal criteria status quo and the hybrid approach are able to satisfy all legislative requirements. However, the status quo is able to meet a wider range of user expectations, including EPA's ongoing need to access the data and forms for enforcement purposes, industry and environmental groups' needs for accuracy, and other users demands for sufficient standardization to perform useful searches on the data base. The hybrid approach offers the potential to meet some of the user needs, but not to the extent that the status quo does. Additionally, the status quo better ensures operational success because data ownership issues do not have the potential to introduce additional delays or problems with producing the national data base into the process. Therefore, the status quo is the most feasible means of continuing to produce the TRI data base, so that it meets all legal and most user requirements. Additionally, planned technological improvements in the status quo approach have the potential to strengthen further the current approach's ability to meet all user requirements. However, because the states are a critical partner in environmental protection, and EPA wishes to continue to increase its involvement with the states, there are opportunities for improving state involvement with TRI. These ix Feasibility Analysis ------- Executive Summary opportunities range from involving the state more in the current process in roles, such as quality control, to further investigating the feasibility of involving committed states in the data entry and verification process. Additional research into the hybrid approach may reveal that the benefits of state involvement outweigh any potential difficulties or loss in ability to meet other requirements, making this a worthwhile approach to pursue. However, if other user requirements cannot be met in a reasonable manner as is indicated by this analysis, then the hybrid approach should not be pursued because TRI has an extensive user base, and each user is a valuable partner in environmental protection. Feasibility Analysis ------- I. Introduction This chapter provides background information on the Toxics Release Inventory, including a summary of reporting requirements and a high-level description of TRI operations. This chapter also explains the impetus and purpose of the study, and Booz* Allen & Hamilton Inc.'s approach to performing the study. Background The 1987 Toxics Release Inventory was mandated by the "Emergency Planning and Community Right-to-Know-Act" (EPCRA) enacted by Congress in October of 1986. This law, also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), is based on the premise that citizens have a "right-to-know" about toxic chemicals in their communities, and has two main purposes: To encourage planning for response to chemical accidents To provide the public and the government with information about possible chemical hazards in their communities. The law requires that EPA make this inventory available to the public in a computer data base. In addition, it requires states to establish State Emergency Response Commissions and Local Emergency Planning Committees to collect detailed information on local manufacturers. Current Legislative Mandate The original EPCRA law requires all facilities in the manufacturing sector - Standard Industrial Codes (SIC) 20 through 39 - that have ten or more full-time employees to report if, during the calendar year, they: Manufacture, import, or process 25,000 pounds or more of one or more of over 320 chemicals Use 10,000 pounds or more of a listed chemical. These reports must be submitted no later than July 1 of the following calendar year. Feasibility Analysis ------- Introduction Congress derived the original chemical list from lists of toxic chemicals developed Tor New Jersey's and Maryland's community right-to-know programs. Maryland's list included chemicals subject to other federal environmental programs and chemicals known to be likely carcinogens. New Jersey listed chemicals that were used or imported into the state and/or the United States in excess of 10,000 pounds per year and those known to cause cancer and other adverse health effects. Facilities that meet these reporting requirements must submit a report for each chemical. Since reporting is based on chemical production or use, reports must be submitted even if no releases are estimated or if the emissions level complies with all federal environmental laws and permits. Information the facilities must report includes the: Maximum amount of chemicals on site during the year Purposes for which the chemical was used Steps taken to treat the waste. Additionally, new pollution prevention requirements have increased the number of data elements. The increase expands the number of data elements required to be reported by approximately 30. For the RY90 form, approximately 60 data elements on average were entered into TRI, compared to the RY91 form which has a total of 90 data elements. Future Regulations TRI is the first government program mandated by Congress to make information available to the public via telecommunications. As a result of this mandate and the interest in the Form R data, TRI has received extensive attention from a diverse group of organizations and individuals, including environmental groups, members of industry, individual citizens, and other government organizations. This attention is continuing to grow as the public asks for access to additional environmental data. This momentum may result in additional reporting requirements for TRI. For example, EPA is considering requiring additional industries, such as federal facilities, mining, agriculture, or utility companies to comply with the reporting regulations of EPCRA, and/or to require the reporting of additional chemicals. In addition, various versions of the Community-Right-To-Know-More Act are under consideration, which, if passed, will significantly increase the number of facilities required to report, the number of chemicals listed, and data elements to be maintained in TRI. As reporting requirements change and the number of reporting facilities and chemicals increase, EPA must be capable of responding to this additional volume and complexity. Feasibility Analysis 2 ------- Introduction Current Process The process by which data are received and entered into the TRI database is summarized below and in Exhibit 1-1. Exhibit 1-1 Required Section 313 Reporting Industries throughout the U.S. £«CD«t» Entry LAW EPA Processing NeiiBMl tat* Pmratlne - . fu. >-| , IMVlWQfl H»««»reh Triwifll* Pmrk, Annual tiii Data to Public ot Date Reconciliation Resolution of l*sue« ol noncompliance and technical errors with Industries Electronic Public Access The process has five main components: Industry submits Form Rs, containing the required reporting information, to the EPCRA Reporting Center (ERC) where they are processed and entered into a Local Area Network (LAN) data base. A sample of this data from the LAN data base is then verified against the original form for accuracy. Records from the LAN database are periodically uploaded to EPA's mainframe computer, which is an ADABAS database, located at the National Data Processing Division in Research Triangle Park (RTP), N.C. ERC staff use terminals connected to the mainframe to run data reconciliation procedures. This involves running data quality reports that assist with analyzing the data for reporter and data entry accuracy, correcting records in the database, and Feasibility Analysis ------- Introduction standardizing data (such as parent company names) across the database. Submitting facilities are contacted, when necessary, by EPA and ERC staff to notify them of noncompliance with the regulation and to resolve technical errors in the data. Data are transferred to the National Library of Medicine (NLM) in segments of approximately 20,000 records each after the data quality/reconciliation process has been completed for each section. NLM indexes and loads the data on TOXNET. Data is also available in Depository Libraries across the country on various other media such as CD-ROM, diskette, magnetic tape and through the National Report and other publications. The hard copy forms for the current year are available for review by the public as soon as the data is entered into the network. Responsibility for operation of TRI has been primarily delegated to two divisions within EPA's Office of Pollution Prevention and Toxics (OPPT), the Information Management Division (IMD) and the Economics and Technology Division (ETD), although other divisions also play a role in outreach, analysis, and other areas. IMD has the responsibility for data management implementation and operations while ETD is responsible for overall program guidance, regulation development, and regulatory interpretation. States also play a role in TRI. Some states currently operate their own systems, which they use to fulfill public requests for data or to perform data analysis for their own usage. In addition, EPA often works with states to verify that the TRI data maintained at Headquarters are the most accurate. Selected states have received grants from EPA to perform data quality checks on their state's subset of the national data. At present, however, no states perform data entry for the national TRI data base. Purpose and Approach Because of the increased volume of TRI data to be processed and the demands from users to have access to the data more quickly, EPA is considering alternative data entry and management approaches. Because several states have indicated interest in performing TRI data entry at the state level, EPA has conducted a study to determine the feasibility of state data entry for TRI through an examination of: The benefits, costs, and management issues raised by decentralized TRI data management approaches Feasibility Analysis ------- Introduction The logistical activities which would need to take place for such an approach to succeed. In order to obtain the information necessary to evaluate the feasibility of moving to a system based solely or partially on entry of data at the state level, a series of interviews were conducted with: EPA Headquarters and Regional personnel involved with TRI State personnel involved with TRI System managers, state, and Regional personnel involved with two other EPA data bases using a state data entry approach. This data collection was based on structured interview guides that were administered through face-to-face and telephone interviews. A copy of the interview guides and a list of interviewees are included in Appendix A and Appendix B of this document. The information obtained in these interviews is used in the feasibility study to address the following issues: Definition of Agency and other user requirements for performance of the TRI system Description of the characteristics of other EPA data bases using state data entry as an input process Definition of alternative approaches using decentralized data entry Definition of criteria to evaluate alternative approaches High level analyses of each of these alternatives, including the costs and benefits Recommendations as to the most appropriate approaches to pursue and the activities that must be implemented to ensure the approaches are successful. By addressing these issues this study will assess the overall feasibility of TRI being based solely or partially on entry of data at a state level. Feasibility Analysis ------- II. Characteristics of Existing Data Bases Using State Data Entry Approach The operations of two existing EPA data bases the Biennial Reporting System (BRS) and the Aerometric Information Retrieval System (AIRS) that currently rely on data entry at the state level were examined. Although neither of these data bases share all of the unique requirements of the TRI program, they provide a useful point of reference for the implementation and operation of state- based data entry approaches. The rest of this chapter briefly describes these two systems, their performance, and any issues relevant to the potential advantages and disadvantages of a state data entry approach for TRI. BRS BRS, which is sponsored by EPA's Office of Solid Waste (OSW), supports the Resource Conservation and Recovery Act (RCRA) program. A reporting requirement for hazardous waste generators and waste treatment, storage, and disposal facilities was included in the May 19,1980, promulgation of RCRA regulations. In the initial years following the promulgation of these regulations, the reporting requirements were suspended due to a lack of information management capabilities at OSW and Office of Management and Budget (OMB) concerns about RCRA paperwork burdens. OSW initiated a number of mail, telephone, and site visit surveys during this period designed to help characterize handlers of hazardous wastes. As a result of discussions with environmental groups and states, EPA agreed to administer a biennial report for hazardous waste generators and receivers beginning in 1983. Purpose BRS describes the demographics of hazardous waste generation and management through the tracking of trends in capacity and waste minimization information. Hazardous waste generators and receivers are required to report on what wastes they generated and how they disposed of them. Waste generators also report on pollution prevention activities. The resulting data are intended to provide an overview of the progress of the RCRA program. BRS data are primarily used internally by EPA and the states. EPA Headquarters personnel use the data to support RCRA regulation development. The 1986 amendments to SARA required states to certify that they have the capacity to handle the wastes generated within their states, either internally or through agreements with other states. The BRS data provide key support to Feasibility Analysis 7 ------- Data Base Characteristics these state efforts by quantifying the capacity of waste treatment, storage, and disposal facilities. The program does not currently have a strong public access focus. The public cannot directly access the data base, either in hard copy or electronic form. Freedom of Information Act (FOIA) requests are currently the only means for the public to obtain the data, although OSW plans to eventually make the information available through the National Technical Information Service (NTIS). Similarities and Differences with TRI The BRS program has both similarities and differences with the TRI program. The two programs are approximately comparable in terms of the number of reporting facilities. There is also some overlap between the two programs; approximately 10,000 BRS waste generators are also TRI reporters. Both programs also involve data that are facility-reported, rather than monitored by the government. TRI has a standard reporting Form R, whose format must be followed whether facilities file on hard copy or electronically. For BRS, reporting on the Federal form is not required, so many different forms and formats are used. The BRS program defines the data elements, and states collect the data how they want. About 20 states use the official EPA form. The BRS program also has more complex reporting requirements, involving a greater number of data elements and many complex technical issues. BRS also differs from TRI because the original legislation called for only a few data elements, which were subsequently deemed to be insufficient for program management. The data elements were expanded somewhat in the draft rule, but additional data needs have been identified since that time. However, a final rule has not been promulgated, leaving EPA with no actual authority to enforce the submission of data that were not included in the draft rule, such as facility-level data. TRI is currently a Federal program. Conversely, BRS is largely a delegated program, with much of the responsibility in the hands of the states and the Regions. Approximately 35 to 40 states have RCRA authority delegated to them; BRS efforts for the remaining states are managed by their Regions. Process The regulated community provides their data every two years, to either the state or the Region, as appropriate. Reporting forms are due to the states and Regions on March 1 of the reporting years. As noted above, many different reporting forms and formats are used; some states combine the BRS data Feasibility Analysis 8 ------- Data Base Characteristics collection with other data collection efforts. The states and Regions handle all data entry. Prior to 1987, after receiving the individual submissions from each facility, the states and Regions compiled the results and sent aggregated data to EPA. Beginning in 1987, a decision was made by OSW to attempt to develop a facility- level BRS data base, so states and Regions were asked to provide facility-level data. However, EPA had no authority to enforce this request, since facility-level data were not included in the draft rule. Once the states and Regions have prepared the data, they are electronically uploaded to the Headquarters system. The uploading software includes data quality checks that allow the exporting of only those records that have valid entries in each field. Additional data quality checks for consistency are performed at the Headquarters level. Performance With regard to timeliness, BRS has not had strong success. The reports are due to the states and the Regions on March 1 of each reporting year. The original plan was for the states and Regions to have the period from March to September to process the data and to submit it to Headquarters, which would then have the national data base available by December or January. This schedule has not yet been met. The 1987 data were released in 1990, and the 1989 data have not yet been released, partly because some states still have not submitted their 1989 data to EPA.2 Much of the reason for the delays in releasing the data have been due to problems with data quality. Headquarters has defined data quality standards for each individual data element by defining valid entries. As noted above, records cannot be exported from the states and Regions into the Headquarters files if any elements fail this data quality check. However, other significant data quality problems exist, primarily relating to reporter errors and non-responses. For example, Headquarters had to abandon its goal of producing a facility-level national data base for the 1987 reporting year due to the failure of many states to provide these non-mandated data. As documented in the report on the 1987 implementation of the BRS reporting program, many other problems exist relating to low response rates for specific data elements, invalid entries, and entries that are logically inconsistent 2 In contrast, the 1989 national data set for TRI, received July 1,1990, was made available to the public in May, 1991. 9 Feasibility Analysis ------- Data Base Characteristics with other information reported.3 There is a significant amount of confusion among reporting facilities concerning technical aspects of particular data elements that results in erroneous entries. As discussed in the 1987 evaluation, any reporter problems that exist are compounded by the fact that most states devote few resources to data quality follow-up with facilities. Perceived Advantages and Disadvantages of State Data Entry Approach Several difficulties have made the implementation of a state-based data entry program difficult, as summarized below: State commitment States have received limited grant money from EPA Headquarters for BRS programs. This has provided them with weak incentives to cooperate or to expend efforts on what is essentially seen as a Headquarters data base. States tend to focus the resources that they do have on the specific data elements that they need, such as those relating to capacity certification. This is a consideration that should be accounted for in any program involving state data entry. A lack of funding and/or a lack of state- related incentives for performing the effort will affect the quality of the program. Reporting standards Legal reporting requirements for BRS have been extremely limited, making it difficult for EPA to enforce reporting standards. The agency, however, is currently taking steps to address this issue. States have historically used a variety of reporting cycles and reporting forms. Thus, not all 1989 BRS data may really be for calendar year 1989, and, as noted, states often collect their own data elements. In any state-based program, efforts to enforce data processing and submission of specific data elements may be difficult. Management commitment Efforts to implement BRS, particularly in the early years, were hampered by the lack of a strong management commitment from Headquarters. This situation has been reflected in the lack of resources provided, in the form of insufficient numbers of Headquarters and Regional staff to manage the reporting program. This situation improved somewhat after 1987, when a major effort was made to reexamine the role of BRS and to improve its operations. TRI has had a strong management commitment at Headquarters since its inception. A continued commitment would be necessary if a state-based data entry approach were adopted. 3The 1987 Biennial Report Forms Evaluation. Information Management Staff, Office of Solid Waste, Environmental Protection Agency, March 20,1989. Feasibility Analysis 10 ------- Data Base Characteristics Some advantages to the state-based approach used by BRS do exist. In particular, the report evaluating the implementation of the 1987 BRS reporting process noted that state personnel generally have knowledge of individual facility operations that allows them to more easily identify errors or omissions in the reported information (resources permitting) than EPA Headquarters. AIRS AIRS, which is sponsored by the Office of Air and Radiation (OAR), directly supports the air data needs of EPA and state agencies to meet requirements of Title I, III, V, and VII of the 1990 Clean Air Act. AIRS is EPA's national repository for ambient air concentration and point-source emission data within the United States. AIRS stores data from more than 10,000 ambient air quality monitors and 50,000 plants. Data are collected from all 50 states, and monitoring is required for the criteria pollutants based on such factors as population, pollutant sources, and geographic area. Point sources emitting more than 100 tons per year of any criteria pollutant (except 5 tons per year for lead and 1,000 tons per year for carbon monoxide) must report actual or estimated annual emissions data. Emissions data is gathered from the facilities through surveys that each state (or local agency) develops. AIRS is comprised of four subsystems: Air Quality Subsystem (AQS) contains measurements of ambient concentrations of air pollutants and associated meteorological data. AQS contains the data from the old SAROAD (Storage and Retrieval of Aerometric Data) system. Air Facility Subsystem (AFS) contains aerometric emissions and regulatory compliance data on air pollution point sources tracked by the EPA and state and local regulatory agencies. AFS merges the data from old CDS (Compliance Data System) and NEDS (National Emissions Data System). Area/Mobile Source (AMS) Subsystem contains estimates of area- wide emissions from mobile sources, forest fires, fugitives, transport, and other large-scale point emissions sources. Geo-Common Subsystem (GCS) contains reference information that is used with all of the AIRS subsystems. Reference information includes codes to identify places, pollutants, and processes. Since data in TRI are facility based, as are data in AFS, this study focused particular attention on that subsystem. Although AFS is not exactly identical to TRI in structure, it does provide the best available means for comparison. 11 Feasibility Analysis ------- Data Base Characteristics Purpose AFS is used by EPA Headquarters and Regions in various means, including as a tool to assist in the estimation of total national emissions. State and local agencies utilize the data as well. States use the data to prepare State Implementation Plans to comply with regulatory programs. In addition, industries, public interest groups, and academia request the information in AIRS via the FOIA process. However, the public does not yet access AIRS on-line. Standard reports are produced using AFS data. These reports include Plant Compliance Summary, Emissions by SIC code, and Distribution of Emissions. These reports, which were developed to respond to recurring FOIA requests for that type of information, are available on-line or through the FOIA process. Similarities and Differences with TRI TRI has both similarities and differences with AIRS. For example, both systems have automated edit checks used in data quality procedures. In addition, some AIRS data are facility reported, and some overlap also exists in terms of the air toxics data maintained in each system. The following are differences between AIR and TRI: AIRS is a state delegated program. TRI is not. AIRS tends to be chemical class specific (e.g., volatile organic compounds), while TRI focuses on individual chemicals. Regional offices are active with AIRS, and assist with quality assurance. TRI has limited Regional involvement. AIRS does not currently allow direct public access. Public on-line access drives TRI and is Congressionally mandated. Data in AIRS do not receive the same level of quality assurance across all fields as TRI data do. AIRS managers are confident about the accuracy of data in some fields, but concerned with the data in others. TRI managers are certain about the data quality levels in all of their data. All data in AIRS are not facility reported. Some data are measures of state activity with respect to inspections and enforcement actions. Other data supplied by the states are listings of permitted amounts, not measures of emissions, etc. All TRI data are facility reported. Feasibility Analysis 12 ------- Data Base Characteristics Some data elements in AIRS allow two entries, one for federal and one for the state version. TRI stores only one set of data received from facilities, with certain limited fields for EPA-supplied data. Process Emissions data that are gathered from the facilities by state and local agencies are entered by state or Regional staff. Data entry approaches vary from state to state depending on the available resources and personnel. For example, some states do direct on-line entry (approximately 20), while other states use their own systems to create a tape which is then converted by EPA. Still a limited number of states submit manual reports to Regional offices where the data are entered. This occurs if the states are not able to enter the data themselves (i.e., insufficient resources) or if they are not interested in doing so. AIRS is then updated nightly. While conducting data entry, states and Regions are supposed to adhere to established coding conventions. States are also required to develop QA/QC plans for ozone data. In order to ensure that quality control procedures were followed, AIRS has automated edit checks and verification is performed on selected data. EPA provides ongoing training to assist states in data entry. In addition, states are partially funded by EPA grants to perform data entry and quality control procedures. Performance AIRS experiences problems with timeliness of the data for various reasons, including problems associated with conversion of the data. In addition, states are often slow in submitting their data to EPA. Because of limited resources and varying priorities at the state level, AIRS data entry can take a lower priority for states. In many cases, the latest set of data in AIRS is not from the most recent year. AIRS also has difficulty in producing a complete and accurate data set. There are coordination problems with the states and EPA as to what is required to be reported, and at what data quality level. Although AIRS managers are confident about the accuracy of data in the fields that are most frequently used, they are concerned with the quality of the less frequently used data. States do not always adhere to coding conventions, and they often lack the appropriate resources to perform adequate data quality checks and even though there are edit checks built into the system, they do not check for all types of error. For example, there are no edits to check data against the previous year's submissions to detect any inconsistencies with the data that was reported in previous years. This edit check is the responsibility of the state or appropriate Region. Also, 13 Feasibility Analysis ------- Data Base Characteristics some states submit permit data rather than actual emissions data, and EPA may not be made aware of this. Perceived Advantages and Disadvantages of State Data Entry Approach The following are the benefits of a state-based data entry approach for AIRS: Data entry for data sets of states actively participating in AFS is often accomplished more quickly than by the Regional entry approach. This approach encourages states to have a stake in AIRS States are more knowledgeable about certain facilities than EPA staff, and facility-level data quality could possibly increase because of this familiarity. The following are difficulties that have made the implementation of state- based data entry for AFS difficult: EPA has difficulty in obtaining all of the necessary data elements from the states, and consequently has some incomplete data sets. Data conversion from state tapes often introduces difficulties that require additional time and money to resolve. Some states lack the resources to adequately perform quality assurance procedures, and consequently data quality suffers in some instances. There is no specific time frame during which states must enter and submit data to EPA. As a result, many states perform data entry only when they are able. For example, some 1989 data have still not been submitted to. EPA. BRS and AIRS Conclusions Through examining these two data bases that rely on data entry at the state level, the benefits and problems associated with this type of data management system can clearly be recognized. Although these two systems are not identical to TRI, they are similar enough to serve as a useful tool for evaluating the feasibility of a system based on state data entry for TRI. One important difference between these two systems and TRI is that these systems support state-delegated programs where states are primary users of the data. Feasibility Analysis 5 ------- Data Base Characteristics TRI, however, is not a state delegated program, and does not possess the more formal state, Regional, and Headquarters relationships upon which these two systems depend. Another major difference is that EPA is required to compile and make available a national set of data for TRI, whereas AIRS and BRS are not required to do so. An obvious benefit of this approach for both BRS and AIRS is that the states are more knowledgeable about the facilities than EPA staff, and could recognize and resolve problems with the data submitted by facilities more quickly. Data entry can also be accomplished more quickly by the individual states if they are active participants, rather than by a centralized system entering all the data. However, if a significant number of states do not participate in the data entry process or submit only selected data elements, this requires additional time and resources for EPA to enter the data for the state. Coordinating with the states is clearly a challenge with both systems. Additional time and resources are required in data conversion if states perform data entry, and do not utilize the appropriate conversion software or experience other problems with conversion. States do not always adhere to the coding conventions and standards for data entry, and consequently data quality suffers. Data quality is also affected when states do not have sufficient resources to adequately perform data quality checks. Also, EPA has, at times, not received all the data that it needs for national purposes because the states are focused on collecting and entering data that support their own needs. As can be seen, there are benefits to performing data entry at the state level, but there are also significant problems. Although the problems associated with this approach may not severely affect the overall performance of these two systems, it is necessary to evaluate these problems with respect to the unique requirements of TRI to determine the feasibility of this approach for TRI. 15 Feasibility Analysis ------- IIL State and Regional Interviews In order to obtain the information necessary to evaluate the feasibility of moving to a decentralized system of data entry, a series of interviews were conducted with state and Regional personnel involved with TRI. These interviews were administered through face-to-face and telephone interviews. The interview guides and a list of interviewees are included in the appendices of this document. Also, a matrix summarizing the results of the state interviews is contained in Appendix C. This chapter summarizes information obtained during the state interviews, including the varying capabilities of the different states, and the ability and interest of the states in performing data entry for TRI. The chapter also discusses the Regional offices' feedback on the role they should play in this process. State Interviews Face-to-face interviews were conducted with personnel from states that currently enter a significant number of TRI data elements themselves, as well as states that do not. These states included:4 Georgia (enters data) California (enters data) Texas (does not enter) North Carolina (does not enter) Indiana (does not enter). Interviews were also conducted with personnel from states that participate in the Forum on State and Tribal Toxics Action (FOSTTA). This organization is intended to foster an exchange of information on toxics-related issues between the states, territories, tribes, and EPA. The following states requested telephone interviews based upon a presentation on this study given at a FOSTTA meeting: Kansas Maryland Utah Ohio. 4 OPPT management selected these states based upon results of the FOSTTA survey and indications of interest from the states. Feasibility Analysis 27 ------- State and Regional Interviews Motivational Factors for States Performing Data Entry Many factors were identified as providing an incentive for states to perform data entry. Included in these motivating factors was the desire to have the data available at an earlier date than is now available through NLM.5 Many states also believe that NLM is difficult to use, and even when data are made available to states through NLM, they still require a significant amount of time to manipulate the data so that they can be used. Although many states voiced a desire for earlier availability of data, some are not currently performing analysis or using the data in such a way that necessitates earlier availability of data. Other states identified the need to have the data earlier to respond to inquiries from the public about TRI data. Other states perform, or would like to perform data entry at a state level because they believe they can obtain higher submitter data accuracy than the federal system . They believe that they are more familiar with the facilities, therefore, they would be able to detect problems with the data more easily than EPA. Most states, however, did not perform data normalization or data verification checks as thoroughly as is currently done at the federal level. Their efforts are focused on ensuring the accuracy of data entry. Still other states perform data entry because they want to have greater control or ownership of the data, and to be able to incorporate revisions more easily. States also track administrative information for fee programs and therefore need to enter the data to track these fees. States that enter data currently are committed to continuing with state data entry, and others without systems are already planning to go forward with developing programs. Many other states that did not have systems indicated interest, but cited inadequate resources to develop their own system. Some of the states that rely upon the national database stated that although they are very interested in TRI data that the data are not currently of sufficiently high priority within the state to warrant initiating data entry programs. Data Usage TRI data are used in various ways by the states, including: To provide information to the public To support programs, such as air toxics and pollution prevention. To develop new management tools, such as emissions inventories To help identify discrepancies with permits 5 All states currently have access to TRIS as data entry proceeds. In addition, the full data set is usually available to the states before all data quality activities are finished and before the data set is made available to NLM. Feasibility Analysis 18 ------- State and Regional Interviews To evaluate health risks To conduct other analyses. Usage of TRI data by the states continues to grow and to become more sophisticated. Benefits Associated with State Data Entry The following are what states perceive as being the benefits of state data entry for the TRI program: Higher submitter data accuracy because state personnel are more familiar with their facilities, can recognize errors, and have a vested interest in correct information Data available in a more timely manner due to smaller number of forms Revisions provided by facilities can be processed and incorporated more quickly State entry creates more of a sense of ownership, interest, and usage by states State entry reduces duplication of effort and may save resources States have closer relationships with facilities and could work with them to reduce reporter errors. These benefits represent some of the driving forces behind states currently performing data entry. Problems Associated with State Data Entry Although states perceive there to be many benefits associated with state data entry, they also recognize the challenges to be faced if they are to perform data entry for TRI. The following are what states perceive as being problems associated with state data entry: Limited resources All states may not buy in States may have only parochial interests Compatibility/normalization of data could be challenging 19 Feasibility Analysis ------- State and Regional Interviews States may not be interested in entering all data elements or conducting extensive quality checks on all elements. States want to emphasize the elements that they use. States do not want the data that they enter to be changed at federal level Forms are currently being sent to two places; difficult to ensure that all forms and revisions are entered and to monitor when they are entered. It was indicated by states that these problems must be evaluated and resolved before a decentralized data entry system could function most efficiently. Regional Interviews Regional interviews were conducted to correspond with state interviews. Personnel in the following Regional offices were interviewed to obtain information on what they perceive as being state data entry issues, benefits, and problems for TRI: Region IV Region V Region VI Region IX. Although Regional staff indicated that they had heard interest from many states in performing data entry for TRI, they were not certain of the feasibility of performing this function with the same standards that are currently used at the federal level. Benefits The following are perceived by Regions as being benefits associated with state data entry for TRI: States could do data entry more quickly and thus have the data available to assist with internal programs, such as the 33/50 initiative, air toxics; data would also be available to Regions quicker Data quality could improve as states often know their facilities better than Headquarters. Feasibility Analysis 20 ------- State and Regional Interviews Although Regions recognize the benefits to states performing data entry, they also recognize the challenges that arise if all states are not committed to performing data entry. Problems Some Regional personnel that were interviewed felt opinion that the problems associated with state data entry would outweigh the benefits. The following are perceived by Regions as being problems associated with state data entry for TRI: Regions are unsure of the interest, commitment, and capabilities of all states; all states will not be interested QA/QC - states do not have as stringent of edit checks as the national data base Data normalization - consistency and standardization of data will be difficult Funding - almost all states will require funding to do data entry, which may not be feasible Community Right-to-Know More requirements could overwhelm the states if enacted. Regional Role The Regional offices felt that they could not play a significant operational role in a state data entry process because of their lack of access to the forms and their belief that Headquarters possesses more TRI expertise. However, the Regions provided the following recommendations with respect to their role: Involve the Regions in an assistance role when the program is initiated and as an ongoing liaison Involve the Regions in administering grants. Some Regional offices indicated that resources might need to be provided to Regions to ensure that the right personnel are available to complete these responsibilities. 21 Feasibility Analysis ------- State and Regional Interviews Conclusion Both the states and the Regions saw potential benefits of the state data entry approach, including higher data accuracy, improved timeliness, and an increased sense of ownership, interest, and usage of TRI data by the states. But state and Regional interviewees indicated that the extent to which the benefits would be realized depended upon many factors. One major factor included the ongoing commitment from states in participating. States currently have a wide variety of capabilities, interests, and usages of TRI data. Therefore, all states may not be interested in, and committed to, performing data entry for the long term. Other states may be interested primarily in fulfilling their needs and not the broader requirements of a national database. State and Regional interviews indicated that for decentralization to work effectively, state commitment is a necessity. Other factors impacting the success of a state data entry approach included the availability of resources and the resolution of many logistical activities that must take place. All states have varying levels of capabilities and available resources, therefore in most cases funds would need to be allocated toward ensuring the states have the appropriate hardware, software, and training to perform data entry. Logistical issues that would need to be resolved include quality assurance/quality control, data normalization and standardization, the processing and assignment of document control numbers to Form Rs, and the revisions to data not only for the current year, but also for previous years. States and Regions indicated that these factors must be sufficiently addressed before decentralization is considered feasible. States strongly emphasized that they needed to participate actively in resolving these issues to ensure that their needs were met as well as national needs. Interviewees felt that the Regional offices should participate primarily in an assistance role, not an operational role. This could involve acting as a liaison between the states and Headquarters and acting as the administrator of any grants. Feasibility Analysis 22 ------- IV. Definition of Criteria for Feasibility To evaluate the feasibility of moving from centralized data entry to a successful decentralized approach for TRI, criteria for the assessment were defined. These criteria were based upon the assessment of the other systems using state data entry approaches as well as an in-depth understanding of the unique requirements and needs of the TRI program and of states capabilities and interests. These criteria fall into three main categories: Legislative Requirements User Requirements Operational Requirements. Each of these criteria categories is discussed below. Legislative Requirements Section 313 of EPCRA, Title III of the Superfund Amendments and Reauthorization Act of 1986, defines certain requirements that must be met by the TRI program. These requirements must be met regardless of the specific approach that is used for data entry. Each of these requirements is summarized briefly below: National data base Section 313 of EPCRA states that, 'The Administrator shall establish and maintain in a computer data base a national toxic chemical inventory based on data submitted to the Administrator under this section." Thus, EPA has a legislatively- defined responsibility for the development of a national, computerized TRI data base. Intended Uses Sections 313(h) of EPCRA states that the TRI data is "intended to provide information to the Federal, State, and Local governments and the public, including citizens of communities surrounding covered facilities." Therefore, EPA must ensure that the data support these uses. Publicly accessible on-line Section 313 of EPCRA states that, "The Administrator shall make these data accessible by computer telecommunications and other means to any person on a cost reimbursable basis." Thus, EPA has a legislatively-defined responsibility for making the TRI data base available on-line and otherwise accessible. Feasibility Analysis 23 ------- Feasibility Criteria Required data elements Section 313 also requires EPA to develop a "uniform toxic chemical release form" for facilities covered by the legislation. The law also identifies certain data elements that must be reported: Name, location, and principal business activities of the facility An appropriate certification of the accuracy and completeness of the report, signed by a senior official Whether each listed toxic chemical present at the facility is manufactured, processed, or otherwise used, and the general category or categories of use of the chemical An estimate of the maximum amounts of each toxic chemical present at the facility at any time during the year The annual quantity of each toxic chemical entering each environmental medium For each waste stream, the waste treatment or disposal methods employed, and an estimate of the treatment efficiency typically achieved by such methods for that waste stream. These reporting requirements have since been supplemented by the Pollution Prevention Act of 1990. Section 313 also defines which industries are subject to TRI reporting, and the threshold limits for releases of listed toxic chemicals. User Requirements Because TRI user groups utilize the data in many ways they hold varying expectations with respect to TRI. As these users have begun utilizing TRI data in more sophisticated analysis, this has increased user requirements in many areas. These expectations are discussed below in terms of accuracy, timeliness, ongoing availability of the present and past years' data and forms, and standardization of the data. As these expectations are interrelated, they are presented in terms of which criteria a particular group prioritizes and on which they would like EPA to focus its efforts. Feasibility Analysis 24 ------- Feasibility Criteria Accuracy The TRI user community, in general, expects the data to be of the highest quality. Users expect data quality to be near 100% accuracy for certain key data fields, particularly those fields that characterize chemical releases, and high accuracy in all other fields as well. A data management process that would ensure near 100% accuracy in critical fields and high accuracy in others would satisfy this criterion. The following provides examples of why this level of accuracy is important to users. Industries are most interested in the accuracy of TRI data because incorrect data can have negative impacts on business. For example, if a release value is either incorrectly reported or entered inaccurately, a facility can receive negative publicity or even potentially be subject to litigation. EPA's enforcement authorities place high emphasis on data quality for similar reasons. EPA needs high quality data in order to perform effective enforcement. If they use data that are incorrect, they could possibly take enforcement action against industries that are in compliance. The scientific community uses TRI data to assist with environmental analyses, so that scientists can understand the environmental quality of a particular area and identify measures that can be taken to improve the quality. Therefore, the scientific community is most interested in high quality data to ensure that environmental problems can be accurately characterized and addressed. Most environmental groups emphasize the importance of retaining the present high level of data accuracy. However, these groups also understand that the data are self-reported by facilities and recognize that regardless of the effort EPA places on ensuring data entry accuracy, there may be errors in the data resulting from inaccurate reporting by the facilities. Ongoing Availability Expectations of the TRI user community include that the data and the original Form Rs must be consistently available and accessible over time. TRI data are often used in trend analysis, so it is crucial that TRI data be available, not only for the present year, but also for preceding years. Therefore, data and Form Rs must be available on an ongoing basis in order to satisfy availability expectations. 25 Feasibility Analysis ------- Feasibility Criteria EPA is concerned with the availability of the data and the Form R for enforcement and other activities. To support development of a case for legal action, EPA must have the original Form R that was submitted by the facility. In addition, EPA must have access to the data and the Form R not only for the current year, but must also have access for the previous years. Therefore, EPA enforcement offices place high emphasis on the availability of the data and the original Form R. Additionally, EPA uses hard copies of forms to verify data base accuracy when anomalies are found in trends. Timeliness The TRI user community emphasizes the need to receive data in a timely manner. Expectations from the environmental community and other users for the release of data to the public through the National Library of Medicine (NLM) range from one to six months after the July 1 reporting deadline with the average expectation being approximately six months. While other users (including EPA) would clearly like the data to be available as soon as possible, they find the current 10 to 11 month delivery cycle to be satisfactory. Therefore, to meet this criterion to satisfy user timeliness requirements the data ideally would be made available within six months. Environmental groups tend to prioritize timeliness. They are very interested in having access to TRI data as soon after the reporting deadline as possible. TRI staff indicate that specific expectations they have heard from environmental groups for the release of data range from one to six months. Some states maintain data bases of the TRI data for their individual state, although few states enter all TRI data. Other states do not have TRI data management programs and, therefore, rely upon EPA to provide the data. As with environmental groups, state government environmental organizations prioritize timeliness. They are interested in being able to access the data soon after the reporting deadline to assist with tracking and regulating toxic chemical emissions, enforcing environmental programs, and responding to public requests. Standardization The TRI public data base is accessed by various users groups, including industry, private citizens, media, public interest groups, and the federal government. These users are highly concerned with standardization of data. Standardization of data refers to the way in which data are entered into the system. In order to perform effective searches, the data being entered into the system (e.g., parent company name or address) must correspond with the name and address already in the system. For example, the name "Dupont" may be Feasibility Analysis 26 ------- Feasibility Criteria entered on one form, while "Du Pont, Inc." is entered on a second. When a search is performed on this data, all relevant records may not be retrieved. Therefore, in order to meet the user requirements for standardization the data must be compatible throughout the entire system across all states so that users can successfully search for data, and perform meaningful analysis on a national basis (i.e., be able to retrieve information on all Du Pont facilities without having to search using a variety of names). Operational Requirements These criteria measure the operational feasibility of the particular alternative or the ease with which an alternative can be implemented. The four criteria that fall into this category are discussed below. Resource Availability This criterion measures the extent to which implementation of the particular data entry approach is feasible within projected resources. Resources include both the personnel that will be needed as well as the funding required for equipment, training, and any other activities necessary to ensure successful entry and maintenance of the TRI data. An approach that can be implemented within the constraints of projected federal and state personnel and funding availability will be considered to meet this criterion. This will be assessed at a high level, meaning that options which clearly would require more resources than are projected to be available will be considered to not satisfy this criterion. Participant Interest and Commitment The success of any data entry approach depends on the interest and commitment of the participants, namely Headquarters, the Regions, and the states or U.S. territories. Therefore, all alternative approaches will be evaluated based upon the interest and continued commitment from potential participants. Commitment will be measured in terms of the interest of the senior management of the organization in allocating time and resources to accomplishing entry of TRI data. This interest and commitment will be assessed, to the extent possible, in an ongoing framework as TRI data must be entered and made available on an annual basis. Data Ownership EPA is legislatively required to make a national data base available to the public. Therefore, each approach must be assessed with respect to its ability to promote aggregation of the data into a national set. Data ownership issues have the potential to constrain compilation and maintenance of this national set if one 27 Feasibility Analysis ------- Feasibility Criteria organization feels strongly that it owns the data and, therefore, its data cannot be assessed, corrected, or normalized (e.g., the Du Pont example above) at another level, such as when the data have been aggregated. Each alternative approach is rated with respect to the extent to which data ownership issues will negatively impact development of the national data base. Reporting Requirement Modifications Congress and EPA are currently considering adding extra reporting requirements for TRI. These potential modifications include the following: Chemical list changes (250 or more additional chemicals) Standard Industrial Classification (SIC) code expansion (10 or more additional SIC codes) Materials accounting data. In each of these cases, either new types of facilities will be required to report or existing facilities will be required to submit more data. These modifications have the potential to add significant numbers of new forms and data elements, which has serious implications for EPA and the states' or territories' abilities to enter and make accessible the TRI data. This criterion will measure the extent to which each alternative approach would be negatively affected by the potential increase in reporting requirements. An approach which is said to meet this criteria fully would be sufficiently flexible to handle the current projected increases in reporting requirements and to adapt to changes in the Form R and the corresponding data elements. Fatal Criteria The graphic on the following page summarizes the criteria that will be used to evaluate the alternative data entry approaches. Several of the criteria have been designated as "fatal" criteria. These criteria were so designated because failure to meet any particular criterion will result in the program not meeting designated legislative requirements or not being feasible with respect to implementation of operations. Therefore, the alternative is not viable and should not be pursued. The remaining, non-fatal criteria define the extent to which the alternative approaches will satisfy various user expectations and the ease with which they can be implemented. In the analysis that follows in this paper, special consideration is given to issues relating to availability of resources. Although this criterion was not identified as fatal, cost considerations could represent a significant barrier to the implementation of a new approach. Feasibility Analysis 28 ------- Feasibility Criteria Exhibit IV-1 0,1 £g 31 VI ll ifi National Data Base Supports Intended Uses Accessible Online Required Data Elements Timely Accurate Standardized Ongoing Resource Availability Participant Interest Data Ownership Additional Reporting Requirements - indicates that alternative is a fatal criterion All legislative requirements are considered to be fatal because failure to meet any of the requirements would keep EPA from meeting its legal obligations. Participant interest is considered fatal because if any participant required by an approach is not committed, then implementation of that approach will not be feasible. The ability to expand to handle increased reporting requirements is also considered fatal because the likelihood that TRI reporting requirements will be expanded over the next five years is very high. If any of the alternative approaches cannot be expanded, then this approach will not be feasible over time. Therefore, it is not efficient to implement a new approach for the very short term. These fatal criteria along with the remaining non-fatal criteria will be used as the basis for the evaluation of alternatives in subsequent chapters. 29 Feasibility Analysis ------- This chapter defines four alternative approaches to entering, performing quality assurance activities, aggregating, and making TRI data available to the public. These alternatives include: Centralized (Status Quo) State-Based State Entry with Centralized Quality Assurance Hybrid. Each of these alternatives is defined below. An evaluation of each with respect to the feasibility criteria will occur in Chapter VI. Centralized (Status Quo) Under the current approach, states play no formal role in the processing of the TRI data to produce the national data base. Although, as required by law, the reporting Form Rs are sent by facilities to both the states and the EPCRA Reporting Center operated by Headquarters, all activities relating to entry, verification, and quality control of the TRI data to produce the national data base are performed by Headquarters at a single central location in Washington, D.C. Some states perform their own data entry and create their own state data bases, but these data are not the basis for the national data base. Some states do assist in data quality efforts, based on grants provided by EPA. Facilities Exhibit V-l EPA «? Toxics Release Inventory EPA produces a national data base that is made available to the public and to the states in a variety of formats, including on-line access through the National Library of Medicine's TOXNET and on diskettes. Feasibility Analysis 31 ------- Alternative Approaches The TRI data processing effort managed by Headquarters is a Local Area Network (LAN)-based data entry system, linking multiple individual PC workstations. Data entry is primarily a manual process with some of the submissions on magnetic media. Certain elements of the data verification and data normalization processes are automated, but manual effort is critical at various stages for tasks such as comparing data base entries to original hard copy reports. LAN-entered data are uploaded to EPA's mainframe, where anyone with access can use the data. All other TRI products are generated from the mainframe version of the data base. This alternative also includes the assumption that, even in the short-term, new technologies, such as imaging and/or optical character recognition, will be incorporated within the basic framework of the existing process to improve its ability to handle an increased workload, particularly with respect to data entry and records management. State-Based This approach involves the states (or territories) performing the activities themselves, including data entry and quality control activities (i.e., identifying both data entry and reporter errors - verification and reconciliation of data). Once these activities are completed, the data will then be uploaded into the national data base maintained on EPA's mainframe. No additional quality assurance activities will be performed on the national data base. If revisions or new forms are submitted after the upload, the state will be responsible for updating the national data base. Therefore in this scenario as illustrated below, the states will be the primary parties responsible for the TRI data base. Exhibit V-2 Facilities States Toxics Release Inventory These states will either use EPA-provided data entry software or will use their own system and provide a magnetic tape or diskette version to EPA. EPA will be required to provide data entry software or conversion programs, training, data entry procedures and standards, and ongoing user support to the states. Additionally, EPA will still be responsible for performing enforcement activities, using the national data base, as the delegation of this function is not expected to occur. Feasibility Analysis 32 ------- Alternative Approaches As access to the forms is a requirement for enforcement activities, the Agency will need to have access to the same sets of forms that the states have. This could be approached in one of several manners. EPA could reconcile the forms that it receives at Headquarters with those maintained by the states. Alternatively, the forms could be sent to just the states, and the states could then copy the forms and send them to EPA. Logistical issues relating to the assigning of Document Control Numbers (DCNs) would need to be resolved. It is assumed that in this state-based approach EPA will need to provide funding through grants to those states that require additional resources to operate the program. These grants will define accuracy and timeliness standards to which the states should adhere. These standards will be determined in discussions between EPA and the states.6 State-Based with Centralized Quality Assurance In this approach, states (or territories) will still be responsible for all data entry as well as some quality control activities, primarily those involved with identifying data entry errors through data verification steps. The states will either use EPA data entry software directly or use their own systems and provide electronic versions of the data to EPA. Data quality activities will be performed by EPA on the national data set once states have uploaded their data. These activities will include some automated edit checks as well as manual checks to ensure high quality data and to ensure that the data elements are sufficiently standardized to be useful. The quality assurance at the centralized level will also include attempts to identify reporter errors similar to the approach used currently by TRI staff. Enforcement activities will also remain the responsibility of EPA. Exhibit V-3 Facilities States EpA 6 EPA in this context is referring primarily to Headquarters EPA and not the Regional offices. Both Headquarters and Regional interviewees indicated that they did not see a direct role for EPA's Regions in the data entry and quality control process because the Regions do not have access to the forms and because they do not have the level of expertise with respect to the TRI data management process that Headquarters possesses. 33 Feasibility Analysis ------- Alternative Approaches To perform these data quality and enforcement activities, EPA will need access to the forms. This access will be provided as discussed in the state-based approach either through obtaining a copy of the state forms or reconciling the forms received at Headquarters with those received in the states. It is assumed that EPA will provide funding through grants to those states that require additional resources to operate the program. These grants will define accuracy and timeliness standards to which the states will be expected to adhere as a condition of the grant. These standards will be determined in discussions between EPA and the states. EPA will also be responsible for providing data entry or conversion software, procedures, training, and other support as necessary to the states. Hybrid Approach The hybrid approach involves a combination of some elements of the approaches described previously. In this alternative, those states (or territories) that are interested in and committed to state data entry will enter data for their state, perform data entry accuracy checks, and upload the data to the national system. Exhibit V-4 States EPA Facilities Data entry under the hybrid method would occur using EPA's data entry software, or conversion software would be provided. For those states that are not interested in participating, EPA will be responsible for entering and verifying their data at a central location. In addition, EPA will perform quality assurance activities on the national data base, focusing on identifying reporter errors and Feasibility Analysis 34 ------- Alternative Approaches ensuring standardization of data.7 EPA will also retain responsibility for enforcement activities. Access to forms will be handled as presented in the state-based and state- based with centralized quality assurance alternatives. It is also assumed that EPA will be responsible for providing funding via grants to those states that have chosen to enter data, developing and providing data entry and conversion software as well as standards and procedures, and providing ongoing user support. Each of these alternatives is evaluated relative to the feasibility criteria in the following chapter. 7 As the previous footnote indicated, these activities are assumed to be performed by Headquarters EPA, not Regions due to the lack of access to the forms that Regions currently experience. 35 Feasibility Analysis ------- VI. Analyses of Options and Recommendations This chapter summarizes the analysis of the four alternative approaches introduced in the last chapter. The first step in this analysis was to evaluate each approach against the fatal criteria defined in Chapter III. Based on this analysis, alternatives that did not meet the fatal criteria were immediately eliminated as these alternatives were not considered to be viable options for TRI. The remaining alternatives were then evaluated with respect to all criteria and the primary benefits and problems associated with each were identified. This chapter presents these analyses and Booz, Allen's recommendations with respect to the most appropriate alternatives to pursue. Criteria Failing to Meet Fatal Factors Six fatal criteria were defined in Chapter IV. Four of these criteria related to TRI's legislative requirements: Need to aggregate data into a national data base Need to support legislatively mandated uses Need to make data accessible on-line Need to ensure that legislatively-mandated data elements are entered into the national data base. The other two remaining fatal criteria measure the feasibility of making each alternative operational. These criteria include: Participants are interested in and committed to the data entry process Alternatives are able to expand to handle increased reporting requirements The chart on the next page summarizes the evaluation of each of the four alternatives relative to the six fatal criteria. At this point in the analysis, no attempt was made to determine which alternative best satisfied each criterion. Rather, each alternative was evaluated to see if it satisfied a fatal criterion to any degree. Feasibility Analysis 37 ------- Analyses of Options and Recommendations Exhibit VI-1 Status Quo State-Based State Entry with Centralized Quality Assurance Hybrid / / v / y *, y 4/ / / \ ^% ^ J f Ay ^ i / / ':' -,* ^SS'* &/ - indicates that alternative satisfies fatal criterion As can be seen from the analysis illustrated in the graphic above, two alternatives state-based and state entry with centralized quality assurance must be eliminated. Both of these alternatives do not satisfy three critical fatal criteria: Required data elements Participant interest Ability to handle increased reporting requirements. In both of these alternatives, all states and U.S. territories must be responsible for data entry and quality assurance for data entry errors. During interviews conducted for this analysis, state interviewees indicated that they were primarily interested in entering only those data elements that they use Feasibility Analysis 38 ------- Analyses of Options and Recommendations directly. Therefore, these alternatives could not guarantee that EPA would be able to meet its legislative requirement to enter all data elements reported on the Form R. Surveys of state and territorial TRI programs conducted by FOSTTA indicate that 25 out of 52 respondents or 48% do not currently have automated TRI data bases. Additionally, these surveys indicate that the funding, emphasis, and involvement of the states and territories with the TRI data vary greatly. Based on these surveys as well as the interviews conducted for this project, it can be concluded that all states and territories will not be willing to commit to talcing on the responsibility for data entry. Finally, all state interviewees stated that if reporting requirements increased significantly, such as would occur with passage of the Community Right-to-Know More Act, they had serious concerns about their state's ability to handle that volume of data. Therefore, these alternatives are not operationally feasible if reporting requirements increase significantly. The remaining two alternatives were then evaluated relative to each of the criteria to determine how well the approach satisfies the criterion. The results of this analysis are summarized below. Analysis of Remaining Options The two remaining alternatives status quo and hybrid were assessed against the 11 established criteria. These alternatives received one of three ratings relative to each criterion: Does not meet the criterion Moderately satisfies the criterion Fully satisfies the criterion. The results of this analysis are illustrated on the following page. 39 Feasibility Analysis ------- Analyses of Options and Recommendations Exhibit VI-2 j ] Does not satisfy criterion Moderately satisfies criterion Fully satisfies criterion Status Quo The status quo alternative was found to fully satisfy all but two criteria timeliness and increased reporting requirements. Weaknesses With respect to timeliness, currently EPA makes the data available to the public between 10 and 11 months after the reporting deadline. States and other user groups are interested in receiving the data much more quickly, on average within six months. Therefore, the status quo is not currently meeting the timeliness expectations of all user groups. One component of the status quo alternative is the addition of image processing and optical character recognition (OCR) technologies. Depending upon the success of these technologies, they could allow the status quo alternative to come closer to user expectations for timeliness. In addition, EPA is trying to increase submissions on magnetic media. If this initiative is successful, this could also enable EPA to come closer to user expectations. The status quo was also not found to satisfy fully the increased reporting requirements criterion. However, the planned incorporation of image processing and OCR technologies in the current process has strong potential for helping EPA better manage the increased volume of forms and data resulting from new reporting requirements. Feasibility Analysis 40 ------- Analyses of Options and Recommendations Strengths The major strengths of this alternative revolve around its ability to meet all legislative requirements, most user expectations, and its proven operational feasibility. The status quo was designed to allow EPA to meet the requirements of the law. The current system contains all data elements, produces a national data base, is accessible on-line and through other means, and supports legislatively-mandated uses. The status quo alternative has evolved to meet sophisticated user expectations with respect to overall data accuracy and standardization. Data entry accuracy of the system exceeds 99%, and accuracy of critical release value fields is even higher. EPA has also invested significant resources in standardizing data and in identifying reporter errors to further improve accuracy. This level of accuracy supports a wide variety of usages, including EPA's enforcement activities. With the status quo, EPA is able to access the original Form Rs easily, so that enforcement and other activities are supported. EPA has demonstrated its commitment to continuing to provide data over the years, so that users' abilities to perform trend and other types of analysis is enhanced. TRI managers foresee no change in this commitment. The status quo is a proven concept in that its operations are ongoing, and EPA senior management is committed to continuing to allocate resources to the program. Because the major party responsible for TRI data entry is the Agency, data ownership issues with respect to preparing the national data set are minimized. Because of this alternative's ability to fully satisfy over 80% of the criteria, the status quo clearly remains a strong approach. Hybrid The hybrid approach was found to satisfy fully six out of the twelve criteria. 42 Feasibility Analysis ------- Analyses of Options and Recommendations Weaknesses The six criteria that were not fully satisfied included: Timeliness Standardized data Ongoing availability Available resources Data ownership Increased reporting requirements. Each of these six is discussed below. Timeliness With respect to timeliness, there are many issues that could potentially hinder the ability of the hybrid approach to meet some users' expectations of production of a data base within six months. States or territories may encounter difficulties during data entry or may have other priorities that take precedence over TRI data entry, thus introducing delays into the process. Managers from other EPA systems with state-based approaches indicated that the latter could be a particular problem with an annual reporting period, such as required under TRI. Staff hired to work on TRI data entry would be given other responsibilities to attend to during non-entry periods. These responsibilities could then interfere with data entry during peak periods. One potential solution to this problem would be to hire temporary staff each year. However, this has implications for training, data quality, and other issues. If states or territories do not adhere to established procedures or standards or if conversion software is not effective, EPA could spend significant amounts of time "cleaning up" the data, so that they meet the users' accuracy expectations. The states with high volumes of forms would need to volunteer to participate in this hybrid approach and do their own data entry to reduce significantly the current time period in which the data are available. If EPA still is entering data for the high volume states, then the majority of the data entry will still be occurring centrally and significant time savings over the current process will not be realized. If the high volume states do participate, there is the potential for the data entry process to be somewhat accelerated. Feasibility Analysis 42 ------- Analyses of Options and Recommendations Overall because of the many potential areas in which the TRI data entry and verification process may be slowed, the hybrid approach was found to only moderately satisfy the timeliness requirement Standardization Standardization of data so that the national data base can be searched and analyzed in a meaningful fashion is critical for supporting many uses. If many different organizations are responsible for entering and checking the accuracy of data, this has the potential to result in different approaches to entering the same data. For example, Du Pont could be entered in different ways (e.g., Dupont) by different organizations making it difficult to search for all records associated with that company. Successful implementation of the hybrid approach would require resolving a number of other issues in order to meet data standardization requirements. It would be necessary to establish data entry standards for states and to perform quality assurance on the national data base to address this issue. The potential for this to be a more challenging process than in the status quo and to take more time is real, resulting in the moderate rating. Ongoing Availability The hybrid ensures the ongoing availability of TRI data because of the strong role played by EPA in this alternative. If a state that has previously agreed to participate drops out, the Agency will be in a position to enter that state's data. The hybrid does not fully satisfy the other component of this criterion, the ongoing availability of the forms. Access to the form is critical for performance of enforcement and reconciliation activities. Because data entry is occurring within different organizations state and federal and because forms are currently sent to both places, it becomes difficult to ensure that EPA has the same set of forms that the state performing data entry has in its possession. EPA and several states have reconciled their forms at various times in the past and have indicated that the same set of forms and revisions is often not sent to both the states and EPA. EPA may have forms from facilities that the state does not have and vice versa. The following options exist for ensuring appropriate access to the forms under the hybrid approach: Reconciliation of forms: Because forms are sent to two places, EPA would need to give the states a range of document control numbers (DCNs) which the states would assign to their forms. The states would then provide EPA with information on what forms, revisions, etc., that it received and the corresponding DCN that was assigned. EPA would compare this information against its forms 43 Feasibility Analysis ------- Analyses of Options and Recommendations and assign the same DCN. Any discrepancies between-the two sets would then be resolved. This approach would have cost implications because the need to reconcile forms from all states would require EPA to invest in extra personnel to perform this function. This could also result in time delays if there are discrepancies or if states do not quickly submit their forms information. EPA would not be able to perform any enforcement or reconciliation activities until the forms were reconciled. Submission of Forms to States: A decision could'be made to treat the forms submitted to the participating states as the "official" Form R submissions for those states, although submission to EPA would continue as well, as required by law. The participating states would copy the forms received and forward them to EPA for use in its activities. This could potentially require additional investments and personnel and slow the overall process if forms are not copied promptly. Once again, EPA could not start any of its enforcement or reconciliation activities until the forms were received. If EPA required access to an original form, they could request the original from the state or attempt to locate the original from among the submissions sent directly to EPA. Either process could potentially be time-consuming and introduce considerable delays. Since EPA has legal responsibility for the national data base, some procedures for ensuring access to the original forms would be required. Submission of Forms to EPA: Another alternative is to send the forms only to EPA. The Agency could then copy the forms and send them to the participating states. As with the previous option, this approach would likely involve additional personnel and has the potential for introducing delays into the data entry process. The use of image processing technology by EPA to make electronic images of the forms accessible to the states could be explored, but the associated communications and hardware costs for transmitting images would likely eliminate this as an option in the near term. Because of all the challenges just described, this alternative does not fully support the ongoing availability of data and forms criterion. Feasibility Analysis 44 ------- Analyses of Options and Recommendations Available Resources Based on the results of interviews, it can be concluded that EPA will be required to provide resources to.the majority of the states that agree to perform data entry. For the purposes of this project, a high level cost analysis has been performed to estimate the additional cost of this undertaking for EPA. This analysis does not estimate total costs, but instead the additional resources EPA would be required to provide as well as the resources the Agency would save by not entering all forms. This is calculated by estimating personnel and equipment costs for those activities that would vary most widely between the status quo and a state data entry approach, including upfront processing, data entry, data verification, training, user support, management, grant oversight, and forms reconciliation. Detailed calculations and assumptions are provided in Appendix D. Based on the state and Regional interviews and the results of the FOSTTA survey, it can be concluded that the perception is that most states would be interested in participating, with some exceptions. Therefore, for the purposes of this cost analysis, it was assumed that 70% of the forms would be entered by the states, or approximately 59,500 forms and 25,500 by EPA. By averaging the number of forms per state and or territory, 70% of the forms can be translated into approximately 36 states and /or territories that would participate. For each participating state and territory, EPA was assumed to provide all necessary personnel and equipment. This could cost the Agency close to an extra $3.6 million each year for personnel and a one time investment of $657,000 for equipment. EPA's costs for data entry and verification could be reduced by about $1.1 million because the Agency is no longer responsible for entry and verification of 70% of forms. EPA would need to add resources to its Headquarters staff to oversee, coordinate, and support the state data entry process. This would result in the need for close to an additional half million dollars each year. This estimate can be broken out as follows: $226,000 per year for user support and training $190,000 a year for overall management and grant oversight $49,000 per year for personnel to reconcile forms. 45 Feasibility Analysis ------- Analyses of Options and Recommendations Exhibit VI-3 State Personnel and Equipment $3,598,279 Savings from EPA Data Entry/Verification l >137,459 EPA User Support and Training + 226,400 EPA Management and Grant Oversight + 190,000 EPA Personnel to Reconcile Forms + 49,038 Total $ 2,926,259 Therefore, it can be seen based on these preliminary estimates that with the hybrid approach, EPA will be investing significantly more dollars each year. EPA will be responsible for one-time costs of approximately $657,000 and additional costs of approximately $3 million each year for personnel in the hybrid approach. If Community Right-to-Know More or other legislative or regulatory changes are enacted, EPA would need to provide the states with additional personnel and equipment to handle the increased volume. This would also require additional EPA personnel to support the states in terms of training, user support, grant oversight, and forms reconciliation. In addition, EPA would not realize as large of savings in its upfront processing, data entry, and verification budgets because the Agency would be handling a larger volume of data as well. The net result would be the need for EPA to invest even more resources for the state data entry approach to be feasible. Data Ownership The hybrid alternative was ranked as moderately meeting the data ownership criteria because most state interviewees indicated that they would not want their TRI data to be changed by EPA if states were responsible for data entry. Yet, other interviewees felt that data quality activities must be performed on the national data set to ensure that it meets users' expectations for accuracy. Because of these views, EPA would retain its responsibility for overall data quality and would need to conduct its usual data standardization activities. However, rather than actually change the data base when errors or inconsistencies are discovered, EPA would ask the participating states to change the data and resubmit to EPA. Thus, state insistence on data ownership would not prevent the development of a standardized national data set, but the procedures necessary to modify data under this alternative have the potential to Feasibility Analysis 46 ------- Analyses of Options and Recommendations increase the amount of time required to make the data available to the public beyond the status quo. Increased Reporting Requirements Interviewees also expressed concern over the states' abilities to continue to perform TRI data entry if reporting requirements increase dramatically as would result from passage of a Community Right-to-Know More Act. This increase in reporting requirements would definitely necessitate additional resources for the states. However, some states indicated that this sort of significant increase might reduce their interest in participating in data entry. Strengths The strengths of this alternative were that it satisfies all the legislative requirements, one user requirement, and one of the operational requirements. The hybrid approach will still allow the national data base to be compiled and to be made available on-line. Only those states and territories that agree to enter all required data elements will participate. EPA will have responsibility for entry of all required elements for the remainder of the states, so that legislative requirement will be met. However, as learned from the experiences of AIRS and BRS, there is the potential that even those states which initially agree may not be able to carry out all responsibilities. So EPA would need to be prepared to assume those responsibilities for that state. The hybrid approach will also ensure accurate data. The participating states will be responsible for verifying their data according to standards negotiated between EPA and the states. Because these states will have agreed to meet these standards and because they are working with a smaller number of forms and are familiar with their facilities, this should result in high data entry accuracy (states interviewed indicated that data entry accuracy for their systems currently ranged from 90 - 99+%). States will need to be required to submit reports on error rates to EPA to ensure that data quality is acceptable. EPA can then identify any problems and take steps to address them. Also, EPA will be responsible for detecting any additional errors and standardization problems in the national data set, and for identifying reporter errors, further strengthening accuracy. This partnership between EPA and the states has the potential to improve upon the levels of accuracy obtained with the existing 47 Feasibility Analysis ------- Analyses of Options and Recommendations system because of the combined facility knowledge and efforts of both parties. The success of these efforts will be dependent on the ability to reach agreement on how forms and edits will be handled for those states that will not relinquish ownership of the data, to ensure that EPA has access to original forms as required for its work efforts. Participation should not be an issue with this alternative because only those states that are interested in participating will be responsible for data entry. States will not be under any obligation or commitment to participate and take responsibility for data entry. If they would prefer not to be involved, EPA will continue to have responsibility for their forms and data. The hybrid approach is almost split evenly between criteria that it fully satisfies and those that it moderately satisfies. However, this analysis is based on "lessons learned" from other systems as well as opinions of interviewees. If difficulties encountered by other systems have been identified and planned for, the potential exists that if actual implementation were pursued, some of the rankings (e.g., standardization) might improve. However, some (e.g., accuracy) could also decrease if unexpected problems are encountered during implementation. Recommendations Based strictly upon an evaluation of the alternatives relative to the criteria, two alternatives are infeasible state-based and state-based with centralized quality assurance because all states and territories: Will not be willing or able to participate Are not interested in entering all the data elements for which EPA is responsible Do not feel that they could perform data entry if reporting requirements increase dramatically. With respect to the remaining two options, the status quo is the most feasible approach to entering, quality assuring, and making the data available to the public as it satisfies ten of the twelve criteria fully and two moderately. This approach ensures that all legal obligations are met, most user expectations (with the exception of timeliness), and almost all operational requirements. (These evaluations assume that the current system is upgraded to incorporate image processing and OCR technologies.) The hybrid approach also fully Feasibility Analysis 48 ------- Analyses of Options and Recommendations satisfies all legal obligations, but does not provide the same level of satisfaction with respect to user and operational requirements as the current approach. However, during this evaluation of feasibility of state data entry benefits associated with increasing state involvement in the TRI program in some capacity have been identified. These benefits include potentially the ability to assist EPA with responding to an increased volume of public queries and assistance with internal, programmatic activities aimed at improving environmental quality. Therefore, regardless of whether or not a decentralized data entry approach is pursued, it is critical that EPA continue to promote the federal/state approach in the context of the TRI program. Because of the interest in promoting this partnership, EPA should consider additional mechanisms to involve states in the current system as well as consider additional research into the feasibility of the hybrid approach. Recommendations in each of these areas are provided in the following sections. Status Quo EPA should consider additional mechanisms for promoting communication and involvement with the states in the existing process as well as for better meeting the needs of the states. Examples of some mechanisms include: Investigate the possibility of expanding the number of states that are given data quality grants to review the TRIS data. This could also increase the involvement of the Regional offices through the grant administration process. Develop a tool for identifying on-line when revisions are entered into the TRI data base, so that the states are able to use the most up- to-date versions. This recommendation is already being addressed for the next reporting cycle (RY91). In this version of the data base, access to both revised and prior data will be available to the states. Implement more state outreach projects, like the ongoing Pennsylvania pilot. This pilot is investigating all potential TRI users in Pennsylvania and is seeking to build a network of organizations (e.g., libraries, poison control centers) across the state that will satisfy the needs of these users. Provide additional funding to train state TRI program personnel in the use of TRIS and NLM, to enhance their access to the data. Implementation of these recommendations would promote further involvement of the states and territories with TRI data even if decentralized data entry is not adopted. This would also provide overall benefits for TRI in terms of 49 Feasibility Analysis ------- > MATERIAL ' ' ? US EPA Ti.- Analyses of Options and Recommendations ;' 401 M ST . .. .,., ^3 [., VVMSI-IINU I U,\. _.;; 20460* $,. (202) 260-3944 increased usage and access to data at the state ancHocal levels throughout the .3 country and well as the potential for higher quality facility-level data. Hybrid The hybrid approach offers more potential for directly involving the states than the current system does and for allowing TRI data to meet the needs of state users. But as described earlier, its ability to meet the expectations of all users and to be operationally feasible is somewhat in question. However, further development of this alternative and research into its feasibility would allow EPA to determine the extent to which user expectations would not be met and operational problems would occur, and whether those potential problems would be offset by the benefits of increased state involvement. Some of the specific issues that would need to be addressed if further development of the hybrid alternative was considered to be worthwhile: Interest How many states and territories are interested in becoming involved in data entry and what capabilities do these states have currently. Level of resources - What level of resources the states need to ensure successful data entry and through what source (e.g., fees, EPA grants). Appropriate quality and timeliness standards - What standards should be met regardless of where data entry occurs Grants tracking - Where are grants going to be tracked, at the Regions or Headquarters? It may be difficult for the Regional offices to track the grants and to monitor overall compliance with data quality and timeliness standards because the Regions do not currently have access to the forms. Enforcement - How will enforcement activities be managed? EPA has currently indicated that it will not delegate enforcement activities, so the specifics of accessing original forms, certifying whether or not a facility reported, and other enforcement activities will need to be worked out if EPA is not responsible for all data entry. Data entry approach - Direct, using EPA software or retain use of state system and convert the data? If conversion software is necessary, the issue of who should pay for and develop the software must also be explored. feasibility Analysis 50 ------- Analyses of Options and Recommendations Data quality - Negotiate specifically what the responsibilities of the states will be vs. EPA. The states should maintain responsibility for verification with EPA the primary responsibility for reconciliation. Training and ongoing user support - How much should be provided each year and should this occur through EPA Headquarters or the Regional offices? This decision is dependent upon issues such as access to the form, current location of expertise, and economies of scale. Access to forms - Should the forms be reconciled and what will this require in the way of resources? Would EPA give the states a range of document control numbers to ensure that an individual form can be tracked? Should forms go only to the state or to EPA and then be copied for the other party? In addition to conducting an exploration of these issues, it may also be helpful to conduct a pilot to test an operational data entry approach, to test resource estimations, and to identify any additional issues that need to be resolved. Conclusion Both of the alternatives that satisfied all of the fatal criteria status quo and the hybrid approach are able to satisfy all legislative requirements. However, the status quo is able to meet a wider range of user expectations and operational requirements, including EPA's ongoing need to access the data and forms for enforcement purposes, industry and environmental groups needs for accuracy, and other users demands for sufficient standardization to perform useful searches on the data base. The hybrid approach offers the potential to meet some of the user needs, but not to the extent that the status quo does. Additionally, the status quo better ensures operational success because data ownership issues do not have the potential to introduce additional delays or problems with producing the national data base into the process. Therefore, the status quo is the most feasible means of continuing to produce the TRI data base, so that it meets all legal and most user requirements. Additionally, planned technological improvements in the status quo have the potential to further strengthen the current approach's ability to meet all user requirements. However, because the states are a critical partner in environmental protection, and EPA wishes to continue to increase its involvement with the states, there are opportunities for improving state involvement with TRI. These opportunities range from involving the states more in the current process in roles such as quality control, to further investigating the feasibility of involving committed 51 Feasibility Analysis ------- Analyses of Options and Recommendations states in the data entry and verification process. Additional research into the hybrid approach may reveal that the benefits of state involvement outweigh any potential difficulties or loss in ability to meet other requirements, making this a worthwhile approach to pursue. However, if other user requirements cannot be met in a reasonable manner as is indicated by this analysis, then the hybrid approach should not be pursued because TRI has an extensive user base, and each user is a valuable partner in environmental protection. Feasibility Analysis 52 ------- Appendix A. Interviewee List The interviewee lists on the following pages are organized as follows: Headquarters Regional State System Managers. Headquarters Interviewees: George Bonina, Office of Pollution Prevention and Toxics, Information Management Division, Deputy Director Ruby Boyd, Office of Pollution Prevention and Toxics, Information Management Division Sarah Hammond, Office of Pollution Prevention and Toxics, Environmental Assistance Division, State Liaison John Harmon, Office of Pollution Prevention and Toxics, Information Management Division Bob Janney, Office of Pollution Prevention and Toxics, Environmental Assistance Division, Regional Liaison Steve Newburg-Rinn, Office of Pollution Prevention and Toxics, Information Management Division, Public Data Branch Chief Janette Peterson, Office of Pollution Prevention and Toxics, Information Management Division Doug Sellers, Office of Pollution Prevention and Toxics, Information Management Division Sam Sasnett, Office of Pollution Prevention and Toxics, Economics and Technology Division Linda Travers, Office of Pollution Prevention and Toxics, Information Management Division, Director Mike Walker, Office of Enforcement, Toxic Litigation Division Mike Wood, Office of Compliance Monitoring, Compliance Division Janet Bearden, Office of Compliance Monitoring, Policy Division Bridget Sullivan, Office of Pollution Prevention and Toxics, Office of Compliance Monitoring, Policy Division Sylvia Bell, CBSI, TRI contractor Maxine Romo, CBSI, TRI contractor David Waggoner, CBSI, TRI contractor ------- Appendix A Regional Interviewees: Helen Burke, Region IX, Pesticides and Toxics Branch Carlton Hailey, Region IV, 313 Coordinator, Pesticides and Toxics Branch Dennis Wesolowski, Region V, Pesticides and Toxic Substances Branch Warren Layne, Region VI, Pesticides and Toxics Branch Bob Hickland, Region VI, Enforcement State Interviewees: Steve Hanna, Chief, Office of Environmental Information, California Environmental Protection Agency Ken Rydbrink, Office of Environmental Information, California Environmental Protection Agency Fred Alvarez, Indiana Department of Environmental Management, MIS Robert Bierman, Indiana Department of Environmental Management, Office of Air Management, Sr. Environmental Manager Skip Powers, Indiana Department of Environmental Management, Emergency Response Branch, Staff Director Barty Titus, Indiana Department of Environmental Management, Office of Air Management, Director Bert Langley, Georgia Department of Natural Resources, Environmental Protection Division, Emergency Response Program Manager Karl Birrts, Right to Know Program, Kansas Department Health and the Environment Cindy Sferra-DeWulf, Division of Air Pollution Control, Ohio EPA Marcia Mays, Toxic Registries Division, Maryland Department of Environment, Program Administrator Emily Kilpatrick, SARA Coordinator, North Carolina Department of Emergency Management Becky Kurka, Pollution Prevention and Conservation Division, Texas Water Commission Ken Zarker, Pollution Prevention and Conservation Division, Texas Water Commission Gena Guo, Pollution Prevention and Conservation Division, Texas Water Commission Feasibility Analysis 54 ------- Appendix A System Manager Interviewees: BUI Laxton, Technical Support Division, OAQPS Chuck Isbell, National Air Data Branch, OAQPS David Misenheimer, Emissions Inventory Branch, OAQPS David Mobley, Emissions Inventory Branch, OAQPS Ron Ryan, Emissions Inventory Branch, OAQPS Howard Wright, National Air Data Branch, OAQPS Jill Vitas, Alliance Technology, contractor to OAQPS George Czerniak, Region V, Chief Air Enforcement Branch Myra Galbreath, Office of Solid Waste, Information Management Branch Kathy Ferland, Texas Water Commission, BRS Joan Allen, Texas Water Commission, RCRIS George Murray, North Carolina Mary K. Marusak, Region VI Terri Mikus, Region VI 55 Feasibility Analysis ------- Appendix B* Interview Guides Interview Guide EPA Headquarters and Regional Program Personnel TRI Performance Requirements 1. What performance requirements must be met by TRI, regardless of who is responsible for data entry and quality control (i.e., with regard to costs, accuracy, timeliness, and other factors)? Please define these requirements as specifically as possible. 2. What is the relative importance of these requirements? 3. What other program objectives are impacted by failure to meet the performance requirements defined above (e.g., making the data publicly available, supporting enforcement efforts)? 4. Are there other logistical components of the TRI program that could be impacted by a change in TRI data entry operations (e.g., EPA's ability to aggregate the data to build a nationwide data set, linking facility data across reporting years)? Please define these other elements, and the potential impacts of changes in TRI data entry procedures, as specifically as possible. Potential Advantages/Disadvantages of a State-Based Data Entry Approach 5. What are your perceptions of the possible advantages and/or disadvantages of a state-based data entry approach for TRI, in terms of the performance requirements discussed above? 6. Do you feel that such an approach has potential for introducing improvements relative to any of the performance requirements discussed above? Why or why not? 7. Do you feel that such an approach has potential for worsening performance relative to any of the performance requirements discussed above? Why or why not? Feasibility Analysis 57 ------- Appendix B 8. Would there be value to a system that involved state-based data entry for selected states, with the current system being retained for other states? 9. What groups/organizations within EPA are currently supporting the adoption of a state-based data entry approach? Outside EPA? Role of Headquarters in a State-Based Data Entry Approach 10. What role do you feel that Headquarters should play in a state-based data entry approach? 11. What are the roles /responsibilities that you feel Headquarters must retain under a state-based data entry approach? 12. Should states handle only data entry, or should they also perform some or all of the data verification and reconciliation steps currently performed at Headquarters? 13. Should Headquarters perform any data verification/reconciliation efforts on the information provided by the states? Role of Regions in a State-Based Data Entry Approach 14. What role should the Regions play in a state-based data entry approach forTRI? 15. What role should your specific Regional office have? 16. What are your perceptions of the relative advantages and disadvantages of incorporating Regional involvement into a state-based data entry approach for TRI? 17. Would your current staff/resources be able to handle these additional roles/responsibilities? If not, how much would your staff/resources need to be augmented? Funding of a State-Based Data Entry Approach 18. What are the options for providing funding for a state-based data entry approach? 19. Which option do you believe is most feasible for EPA to implement? Feasibility Analysis 58 ------- Appendix B 20. Do you believe that a state-based data entry approach would be cost- effective? 59 Feasibility Analysis ------- Appendix B Interview Guide States Background Information 1. Do you have your TRI data entered into a computer? 2. If you do not have your TRI data in a computer do you plan to enter it into a computer? Why or why not? If no on question 1, skip to question 28. 3. What motivated your state to set up their own system? Costs/Funding/Staffing 4. How is it funded? by grants? state funds? 5. Have you ever received a grant from HQ for state data entry? If so, how was it used? 6. How many staff (full-time and part-time) are working on the TRI program? 7. What kind of hardware/software do you use? 8. Do you think this hardware/software can adequately grow and handle a significant increase in data? 9. What was the state's capital investment? State Data Entry Process 10. Please describe how your state data entry process works? 11. Do you enter all or only part of the data? If only parts, which parts do you enter? 12. What sort of data quality procedures do you follow? 13. Does the state adhere to data entry and other standards established by EPA? Feasibility Analysis 60 ------- Appendix B 14. What level of data accuracy is attained with the system? How is the accuracy measured? 15. What types of data normalization (i.e., standardization) activities occur? At what point in the process? 16. At what point are data aggregated or uploaded to the system? 17. Are any data quality or normalization (i.e., standardization of data elements) activities undertaken on the entire data base? 18. Is there any involvement of Regional offices? 19. If regions were involved do you think this would be one more chance for error? 20. How many Form Rs do you receive and process? 21. How many data elements are entered on average each year? 22. Approximately how much does it cost on average for states to do data entry - per data element? 23. How soon after the July 1 reporting deadline is computerized TRI data available? to staff? to the public? 24. Is this after all data quality/normalization activities have taken place? 25. Do you update your state TRI data base to include revisions? If yes, how often do you revise the data? 26. Do you reconcile your data with Headquarters TRI data? 27. Do you adjust your data base reports/runs to reflect new chemical listings or modifications? 28. Pollution Prevention Act data is included on this year's Form R. Do you plan to include this data in your computerized data base? 29. How much do you think it would cost for your state to enter all TRI/PPA data, assuring 99.5% data entry accuracy? Feasibility Analysis ------- Appendix B Data Users and Uses 30. How do you use the data? 31. Do you use the data for enforcement action? 32. What difference does it make to you if the data is available in December or May? What uses necessitate it to be available in December? 33. Who are the users of the data? 34. Does the level of accuracy in your data base meet the needs of the users? 35. Does the timeliness in terms of availability of the data meet the needs of your users? 36. Do you make the TRI data available to the public? If so, how? 37. Can the public access this TRI computer data base? How? What methods? 38. Do you create customized reports from your data base? 39. Do you respond to public queries? 40. How many requests for information from the public do you receive? 41. What type of requests do you receive (e.g., written, telephone)? 42. Do you charge for your services? If yes, how much? 43. Do you help the public interpret the data by providing them with health effects or risk analysis information? Advantages and Disadvantages of State Data Entry 44. What do you see as the benefits of state data entry? 45. What do you see as the problems with state data entry? 46. How would you improve the state data entry process? 47. How much do you think these suggested improvements would cost? 48. What type of hard ware/software do you use? Feasibility Analysis 62 ------- Appendix B Questions for States Without Systems 49. What type of hard ware/software do you use? 50. Do you think that this hard ware/software can be adequately expanded and grow to handle a significant increase in data? 51. How many staff do you believe would be required to support TRI state data entry? 52. What do you think would be the state's capital investment to conduct state data entry, assuring 99.5% data entry accuracy? 63 Feasibility Analysis ------- Appendix B Interview Guide System Managers Background Information 1. Please describe the basic purpose of your system and the types of information that it contains. 2. Please categorize the users (e.g., industry, environmental groups) of the data? 3. Does the public have direct access to the data base or to its data? 4. What types of analyses can the data support? 5. How are the data used? Is a certain level of accuracy necessary for supporting the various uses? 6, What level of enforcement activities are conducted for this program? 7. What type of entry cycle does the system follow (i.e., continuous, based on a reporting deadline)? 8. How many forms are submitted? What is the average number of data elements? Are they formatted or free text? 9. How long does it take to enter a form, all forms? 10. How soon after receipt by the states are data given to Headquarters (average, worst case scenario)? How soon are data available to the larger user community? Feasibility Analysis 64 ------- Appendix B 11. Have the states always been responsible for data entry? If not, why did the approach change? Process Discussion 12. Please describe how the state data entry process works. 13. Is data entry conducted on the EPA mainframe or at a remote site? How is the EPA mainframe updated? 14. At-what point are the data aggregated or uploaded to the national system? 15. Did states develop their own software or did EPA give them the software? 16. Did EPA establish data entry and other standards to which the states must adhere? Are copies of written standards available? 17. What, if any, is the involvement of the Regional offices? 18. At what point does Headquarters become involved? 19. Who monitors progress, production schedules, etc.? Data Quality 20. What specific data quality procedures do the states follow? 21. What is the level of data accuracy in the system? What level is expected/required? 65 Feasibility Analysis ------- Appendix B 22. What types of data normalization activities occur? At what point in the process? Who ensures consistency nationwide? 23. Are any data quality or normalization activities undertaken on the entire data base? Funding 24. How are the state data entry programs funded? 25. Did the states have to make any significant capital investments to perform their responsibilities? Where did equipment, software, and staff come from? 26. Approximately how much does it cost on average for states to perform data entry - per data element, per form? How does this compare to the federal cost to perform data entry activities? Benefits/Problems 27. What do you think are the benefits of state data entry? 28. What do you see as the problems with state data entry? 29. How would you improve the state data entry process? 30. Are there coordination problems with the states? Feasibility Analysis 66 ------- Appendix B Questions for Regional Staff Involved with System 1. What is your involvement with the system? 2. Please explain the Regional office's responsibilities with respect to data entry and /or quality control. 3. In what capacity, does the Regional office interact with the states with respect to this system? 4. What do you see as the benefits of the Regional office's involvement? 5. What do you see as the problems with Regional involvement? 6. In your opinion, what are the benefits of state data entry? 7. What are the problems with state data entry? 8. How would you improve upon the existing process? 9. Have you encountered data quality problems with the data base? What are they? How have they affected your use/confidence in the data base? 67 Feasibility Analysis ------- *§ 53' State Capabilities Enters data into a computer Plans to enter PPA data Number of data elements entered Number of facilities/forms Date by which data are entered Hardware/ software QA procedures Level of accuracy #ofFTEsfor TRI-reJated work Texas Tracking data No Approx. 5 1200/ 6000 Sept. fee data PC/ Paradox N/A N/A 1 full-time + part-time California Yes No All but, chemical use, waste mlm PPA 1800/ 6000 Sept. PC/ Oracle Automated checks & manual verification of CAS and emissions; dataentrv ' 99+% 1* asst part-time 1 Indiana Data from natl system No Subset only 900/ 3300 N/A Mac/ spread- sheet Internal state review of data N/A 1 North Carolina Facility info. No Approx. 15 1100/ 2500 Sept. PC/ dBase 100% verification of data elements N/A 1 Georgia Yes Yes 90% 730/ 2470 Sept. or Oct. PC/QA software Automated checks; 15% verification; 100% check over Imillion Ibs. 90+% 1 Utah Yes Yes All except, waste min., 120/450 Sept. PC/ dBase 100% verification of data elements 100% 2.5 Kansas Yes Yes All 230/900 Sept. AS400/ Hazox N/A unknown 10 Ohio Yes Not certain All exc. waste mln., lat/ long, POT W, stream 1,600/ 6500 Sept. PC 100% verification of data elements N/A 5 Mary- land Yes Yes ID Info, and 33 fields for chemicals 230/800 Sept. PC/ dBase 100% verification of data elements 90% ! 1 ------- - | State^^ | ^^-""Capabilities I Data uses 1 Form Rs Hied i Creates customized ! reports i Public can access i system on-line i Data available to I public j Publishes annual i report ] Funding Interest in state entry jRequire funding JExtra FTEs i required Texas Reports, toxic loadings, air tones, permits, public, risk assessment Yes Yes No 100 requests/yr. Yes Fee Program - $100,OGO/ year Yes, grant application Yes, will consider fees Yes California Air toxics, pollution prevention, ozone, public requests Yes Yes No 1210 requests over 4 years No Funds from hazardous waste program; all state funds Yes, consd. for Region Yes, will consider fees .5-1 Indiana Air toxics, health effects, inspections Yes Yes No 100 requests/yr. In 1987 Fed. grant for data use; no dedicated funding Yes, not top priority Yes, will consider fees 2+ equipment Carolina Responds to public requests for Form Rs Yes No No 15-20 requests per year No State funds Yes Yes 4+ equipment Georgia Air toxics, permitting, compliance, emergency response Yes Yes No Yes Yes Fed. grant for 311, 312, added 313; no dedicated funding Yes Yes 3+ equipment Utah Air toxics, and other environ. programs, public requests Yes Yes No Yes Yes State funds Yes, will consider Yes No Kansas Reports, toxic loadings, air toxics, permits, public, risk assessment Yes Yes Yes 175 equests/yr. Yes State general funds, fees, grants Yes Yes 0-.5 Ohio Air toxics, permits, public, stream analysis Yes No No Yes Yes Fees, grant Yes No No Mary- land Inspections, permits, air-mgmt, 33/50 analysis, briefings j Yes Yes No ; Yes i No 1 State funds i Yes I Yes Yes a a, n ------- Appendix D. Cost Analysis Assumptions Cost Analysis Assumptions 1. Because this is a high level analysis intended to give EPA an estimate of additional costs involved with or saved as a result of state data entry, only personnel and equipment costs for the components that would vary most widely between the status quo and state data entry were estimated. These included upfront processing, data entry, verification, training, user support, management, grant oversight, and forms reconciliation. 2. State personnel are assumed to be able to perform upfront processing (e.g., opening, date stamping) at the same per hour rate as the current EPA contractor personnel. 3. Peak period for upfront processing for states was assumed to be 1 month on average with 3 months on average for data entry and data verification. These time frames are necessary to ensure that along with EPA quality assurance activities the data can be available within the 6 month target. 4. Peak period for the current system for upfront processing is 3 months and 6 months for data entry and verification. 5. All salary estimates are based upon Labor Rate Surveys and the GS schedule. 6. It was assumed that EPA would fund all personnel involved with entering and/or verifying TRI data for all states as well as most equipment. 7. Each state participating in data entry was assumed to require a LAN which EPA would fully fund. If states plan to use their own systems, then they would receive funding in the same amount as the equipment to develop conversion software or to enhance the existing system to meet performance expectations. 8. In addition to the personnel necessary for data entry and verification, each state was assumed to need one manager - the equivalent of a GS-12 to oversee the state operations. 9. It was assumed that in the status quo approach one manager can supervise 15 personnel (workyears). Feasibility Analysis 71 ------- Appendix D 10. It was assumed that EPA would need to hire additional personnel to perform coordination and oversight functions. 11. EPA will need to train all states approximately once a year to ensure that they are familiar with any changes to software. This number was derived from discussions with other EPA system managers involved with state data entry. EPA employees will visit each individual state to assist with installing new software, training, and overseeing data entry functions. Each trip was assumed to cost $1000. 12. User support in the form of a hotline will also be provided at EPA. 13. Additional personnel will be required to oversee the grants and to ensure that data entry and verification efforts are coordinated across states and between EPA and the states. 14. For the purposes of this cost analysis, it is assumed that EPA will be responsible for reconciling its forms against those held by the states. This will involve EPA providing document control number ranges to the states and then matching its forms against those in the state data base. Additional personnel are required for this function. Feasibility Analysis 72 ------- Appendix D PERSONNEL RESOURCES NEEDED BY STATES and EPA Assume 70% of forms entered by states Forms entered by EPA Total Forms Forms/hour for upfront processing Hours per 1 month peak period - state upfront processing Forms/hour for TTS keying (first component of data entry} Forms/hour for TRIS keying (second component of data ent Hours per 3 month peak period; state data entry and verifi Forms/hour for verification Hours per 3 month peak period - current upfront processing Hours per 6 month peak period - current data entry and ve Number of Managers Needed/State Number of Managers Needed by EPA for each 15 Workvears state Estimates for 70% of Data Entry, Verification Hours Required for State Upjront Processing Workyears for State Upfront Processing Hours Required for State TTS Keying/Year Workyears for State TTS Keying Hours Required for State TRIS Keying/Year Workyears for State TRIS Keying Hours Required for Verfication Workyears Required for Verification Total Workyears Required for States Average Workyear/State Total Number of Managers Required for States EPA Savings Hours Required for EPA Upfront Processing Workyears for EPA Upfront Processing Hours Required for EPA TTS Keying/year Workyears for EPA TTS Keying Hours Required for EPA TRIS Keying/Year Workyears for EPA TRIS Keying Hours Required for Verfication Workyears Required for Verification Total Workyears Required for EPA Managers Rec Cost/Year for uired for Supervision Upfront Processing Personnel 59500 25500 85000 12 160 10 * 480 7 480 960 1 1 4822 30 6128 13 23611 49 9070 19 111 3 36 4822 10 6128 6 23611 25 9070 9 50 3 $19,500 73 Feasibility Analysis ------- Appendix D Cost/Year for Data Entry Personnel Cost/Year for Verification Personnel Cost/Year for Managers (equivalent to a GS-12) Total State Cost for Personnel to Process, Enter, Verify 70' Total Cost for State Managers Total Cost for State Personnel Total EPA Savings EQUIPMENT COSTS - Non-recurring Average Number of Forms/State Total Number of States Participating Equipment Necessary Per State for Data Entn File Server Cost Cost for Two Workstations/State Printer Cost Total Cost for File Servers Total Cost Workstations Total Cost Software Total Cost Printers Total Equipment Cost I $20,000 $20,550 $38,000 $2,215,079 $1,383,200 $3,598,279 $1,137,459 1635 36 $8,000 $8,000 $2,000 $291,200 $291,200 $2,000 $72,800 $657,200 ADDITIONAL RECURRING RESOURCE REQUIREMENTS FOR EPA Training and User Support Workyears Required 5 (based on each state being trained each year and telephone support) Cost per Workyear (equivalent to a GS-12) Total Cost for Additional Training Cost for Travel per Trip Total Cost for Travel/Year MANAGEMENT AND GRANT OVERSIGHT WORKYEARS Management and Grant Oversight Workyears Required Cost per Workyear (equivalent to a GS-12) Total Cost for Management and Grant Oversight I $38,000 $190,000 $1,000 $36,400 5 $38,000 $190,000 Feasibility Analysis 74 ------- Appendix D FORMS RECONCILIATION COST Reconciliation Rate/Hour Reconciliation Workyears Required Cost /Workyearfor Forms Reconciliation Total Cost for Forms Reconciliation Workyears Total Recurring Costs for State Personnel Total Additional Recurring Costs for EPA EPA Savings from Not Performing Activit ADDITIONAL EPA COST/YEAR ADDITIONAL EQUIPMENT COSTS 20 2 $24.000 $49,038 $3,598,279 $465,438 $1,137,459 $2,926.259 $657,200 75 Feasibility Analysis ------- EPA U.S. ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 ------- Illtl xx pi & . .- :'x';K::Vx:;r::' | . : ' :i:: ..... SS - Interview Summary August 3,1992 This document was prepared by Booz-Allen & Hamilton Inc., under Delivery Order 112 of EPA/OARM Contract #68-W9-0037. ------- Interviews were conducted to collect the information necessary to evaluate the feasibility of state data entry for TRI data. Interviews were conducted with the following personnel: EPA Headquarters personnel EPA Regional program personnel State personnel Managers of other EPA systems with state-based data entry approaches as well as Regional and state personnel involved with these systems. ------- ------- Personnel in the following offices were interviewed to obtain information on what EPA Headquarters offices perceived as being state data entry issues, benefits, and problems for TRI: Information Management Division in the Office of Pollution Prevention and Toxics (OPPT) Environmental Assistance Division in OPPT Economics and Technology Division in OPPT Office of Compliance Monitoring Office of Enforcement. ------- EPA Headquarters personnel indicated that if states were to perform data entry for TRI they would need to meet the following performance requirements to ensure that legislative requirements and user expectations were satisfied: Data accuracy standards 99.5% data accuracy for data entry Near 100% accuracy in critical data fields (e.g., release amounts over 50,000 Ibs) 95% accuracy for all other values Data of sufficient consistency to facilitate searching Timeliness - have the data ready for release to the public nine months after the filing deadline Cost - must work within budget constraints Availability - must make the data available through many sources and accessible in various formats; data must be available in a national data base i ------- EPA Headquarters personnel also discussed the following specific internal uses for the TRI data, which will need to be supported regardless of who has primary responsibility for TRI data entry: Producing the national report Targeting inspection and enforcement efforts and identifying potential nonreporters and submitters of false data Negotiating pollution prevention settlements Responding to requests for information regarding specific enforcement cases Performing economic analyses of impact of changes in reporting requirements, such as listing/delisting of chemicals or midifying the reporting thresholds. ------- The following are perceived as being benefits of state data entry: State data entry promotes buy-in from the states Some states collect additional information now, and EPA could possibly use this information States are more familiar with the facilities in their own state, and could recognize errors in data submitted more easily Potential for improved access to information at local level. ------- The following are problems that Headquarters personnel perceive as being associated with the states performing TRI data entry and meeting TRI performance requirements: Legal and Regulatory Issues The law requires that there be a national data base for which EPA is responsible Trade secrecy is not delegated to the states Enforcement responsibilities will be maintained at the federal level Notices of noncompliance and technical error are presently done at the federal level For compliance purposes, it may be difficult to get states to perform current Headquarters role of certifying that a given facility did not report, which sometimes requires witnesses to testify in court. ------- Form R Issues Form R processing and retrieval could be difficult since states do not assign document control numbers Access to the "official" copy of the Form R could be a problem if it is kept in the state. Reconciling the national set of forms to the state set could also be challenging. If a cutoff date is established for new forms and revisions, it would be difficult to coordinate with all states. ------- r$'i «v /, ataEnt - S " -V nt -*"* jjV v"*4 Resources Even if resources were available for new technologies, the benefits associated with economies of scale for new technologies would not likely be attainable due to smaller universe of forms being processed by a given state. States could not do the same work for the same amount of money. Concern about lack of sufficient funding to support the program. For states that currently perform no entry of the TRI data, significant resources would be required for training and for establishing a program. If grants are selected as the primary funding source for a state data entry program, consideration must be given of the resources required for grant oversight. State data entry program has potential for increasing burden on Regional resources, which is where most compliance resources are located. Cost savings are likely to be limited because much of Headquarters overhead would not go away (e.g., all forms would still need to be stored); possible cost savings would be further limited if Headquarters still had to enter data for some states. 10 ------- TRI Data Management Issues Requirement for meaningful use of a national data base means that Headquarters would still need to perform data reconciliation activities to ensure consistency of data Since Headquarters needs to perform data reconciliation activites, data ownership could not be given to the states It may be difficult to know which version of the data is available if states submit by batch files If states input and interpret data and send them to EPA it is risky because data do not come from the facility, but rather from the state. Also, each state may interpret data differently There is concern that the data quality checks may not be as stringent at the state level as those currently in place Data normalization so that data are accessible for searches may be difficult if states do entry (e.g., facility and chemical name) If states are unwilling to allow EPA to modify data in any way, it may be difficult to ensure data quality. n ------- State Commitment and Participation Issues Not all states will be able or interested in doing data entry, so Headquarters might still have to perform some data entry. States must remain committed to the program to ensure that data are available over the years. There is currently no means to ensure state compliance with policies and procedures; Headquarters resources would need to be committed to these efforts. States are likely to lack the incentive to enter every TRI data element because they do not use all elements. Possible that states' closer relationships with industry could result in pressure to present data more favorably. 12 ------- The following are recommendations received from Headquarters personnel about how to approach state data entry if such an approach is decided upon: Make certain levels of accuracy and time frames in which entry is to be completed requirements of any grants Provide states with entry software, including NAM/ADD file, and guidance for submissions of tapes/diskettes Provide states with a range of document control numbers for their facilities Continue at least limited data reconciliation and QA on the national data base Perform random QA checks the first year to ensure appropriate level of accuracy ^ Do not involve Regional offices in data entry Provide sufficient funding to support the program adequately. 13 ------- ------- fcc^r :^N>;:?:, jj,;-,: ^^-^^-4^;^^, : Personnel in the following Regional offices were interviewed to obtain information on what they perceive as being state data entry issues, benefits, and problems for TRI: Region IV Region V Region VI Region IX. 15 ------- The following are perceived by Regions as being benefits associated with state data entry: States could do data entry quicker and thus have the data available to assist with internal programs, such as the 33/50 initiative, air toxics; data would also be available to Regions quicker Data quality could improve as states often know their facilities better than Headquarters. 16 ------- || The following are perceived by Regions as being problems associated with state || data entry: Regions are not sure of the interest, commitment, and capabilities of all states; all states will not be interested QA/QC - states do not have as stringent of edit checks as the national data base, and data quality could suffer Data normalization - consistency and standardization of data will be difficult Funding - almost all states will require funding to do data entry, which may not be feasible Community Right-to-Know More requirements could overwhelm the states if enacted. 17 ------- EPA Regional personnel provided the following recommendations for a state-based data entry approach: Planning and Organization Invest in initial training and development of procedures for the states and provide ongoing support Ensure that state organization most interested in using the data is responsible for the entry Procedural Recommendations Negotiate with states to determine appropriate procedures and standards Stipulate requirements in grants for accuracy and time Ensure that Headquarters still performs some quality assurance on the national data base Target 6 months to make data available if entry is moved to states. 18 ------- fcffittry; < AS s. . AJ j&Qv f _. _. ^*j_ * Regional Role Recommendations Involve the Regions in an assistance role when the program is initiated and as an ongoing liaison Involve Regions in administering grants. One Region indicated that resources would need to be provided to Region to ensure the right personnel are available to administer grants Investigate regional data entry approach where one state enters data for all states in the Region. California has considered doing this for Region IX. 19 ------- ------- . ' ' "-'': :';> Ivl'l'&l-X';!!fr'X'l- '''-'' '";' :';'; ,-. ',; :';,';::'; .-''; -": ki-t'tfwwR '''' ' '' ''''''''''''''''''''''''''' ifiiS;:;:* Wm^sfsmM^xf-Sm :: ....-: Interviews were conducted with personnel from states with active TRI data management programs. These states include: California Georgia Interviews were also conducted with personnel from states with less-developed TRI data management programs. These states include: Texas North Carolina Indiana. 21 ------- Interviews were also conducted with personnel from states that have members on the Forum on State and Tribal Toxics Action (FOSTTA). The following states requested interviews based upon a presentation on this study given at a FOSTTA meeting: Kansas Maryland Utah Ohio. 22 ------- The following were identified by states as being motivational factors for performing data entry at the state level: Earlier availability of data Higher data accuracy Greater control over data NLM is not easy to use Need to track administrative information for fee programs Problems with incorporating revisions. States that enter data currently are committed to continuing with state data entry. States that did not have systems cited inadequate resources and insufficient usage of TRI data to justify developing then* own system. Some of these states that rely upon the national database indicated that TRI data are not of sufficiently high priority within the state currently to warrant initiating data entry programs; others are already planning to go forward with their own data entry. 23 ------- The following were identified as being the largest current uses of the data: To provide information to the public To support programs, i.e. air toxics, pollution prevention Other current uses of the data include: To develop new management tools, i.e., emissions inventory, help identify discrepancies with permits To evaluate health risks, i.e., those associated with construction applications and various permits To conduct analyses, e.g., toxic loadings. 24 ------- I The following are what states perceive as being the benefits of state data entry: Higher data accuracy because state personnel are more familiar with their facilities, can recognize errors, and have a vested interest in correct information Data available in a more timely manner due to smaller number of forms Revisions provided by facilities can be processed and incorporated more quickly State entry creates more of a sense of ownership, interest, and usage by states State entry reduces duplication of effort and may save resources States have closer relationships with facilities and could work with them to reduce reporter errors. 25 ------- The following are what states perceive as being problems associated with state data entry: Limited resources All states may not buy in States may have only parochial interests Compatibility/normalization of data could be challenging States may not be interested in entering all data elements or conducting extensive quality checks on all elements. States want to emphasize the elements that they use. States do not want the data that they enter to be changed at the federal level Forms are currently being sent to two places; it will be difficult to ensure that all forms and revisions are entered and to monitor when they are entered. ------- The following are recommendations made by the states with respect to jj their data entry: jj Data Elements: I Consider utilizing only data elements currently entered, enter j remaining at federal level I Consider entering critical data (e.g., releases) first and making || available immediately 1 Allow states the flexibility to request additional information from jj facilities on the reporting form and to maintain this data to support j their work* I Data Changes/Revisions: 1 Allow only the states to make changes to data || Limit the number of revisions that can be submitted each year | Develop a tool for identifying when revisions or updates have been made || I Under the law states can now request supplemental information from facilities. 27 ------- Management and Financial Assistance: Provide recommendations to states on how to organize and staff this function Provide the states with software. Provide conditions in grants to encourage receipt of quality, timely data Provide states with appropriate equipment. State and Federal Communication: Have forms submitted only to states; copies made for EPA Develop communication mechanisms to ensure coordination between states, Regions, and Headquarters Establish standards initially and provide them to the states on issues, such as facility name and other QA measures; work with states to develop these standards. 28 ------- 29 State Capabilities Enters data into a computer Plans to enter PPA data Number of data elements entered Number of facilities/forms Date by which data are entered Hardware/ software QA procedures Level of accuracy ftofFTEsfor TRI-related work Texas Tracking data No Approx. 5 1200/ 6000 Sept. fee data PC/ Paradox N/A N/A 1 full-time + part-time California Yes No All but, chemical use, waste mln., PPA 1800/ 6000 Sept. PC/ Oracle Automated checks & manual verification of CAS and emissions; data entrv 99+% 1+ asst. part-time Indiana Data from natl system No Subset only 900/ 3300 N/A Mac/ spread- sheet Internal state review of data N/A 1 North Carolina Facility info. No Approx. 15 1100/ 2500 Sept. PC/ dBase 100% verification of data elements N/A 1 Georgia Yes Yes 90% 730/ 2470 Sept. or Oct. PC/QA software Automated checks; 15% verification; 100% check over Imillion Ibs. 90+% 1 Utah Yes Yes All except, waste min., 120/450 Sept. PC/ dBase 100% verification of data elements 100% 2.5 Kansas Yes Yes All 230/900 Sept. AS400/ Hazox N/A unknown 10 Ohio Yes Not certain All exc. waste mln., lat/ long, POTW, stream 1,600/ 6500 Sept. PC 100% verification of data elements N/A 5 Mary- land Yes Yes i i i ID info, and 33 fields for chemicals i 230/800 Sept. j j PC/ dBase 100% verification of data elements 90% 1 ------- 30 | state^^^ I ^^''Capabilities ! Data uses j Form Rs filed i Creates customized ; reports I Public can access i system on-line i Data available to j public i Publishes annual j report 1 Funding Interest in state entry jRequire funding Extra FTEs i required Texas Reports, tOXK loadings, air tones, permits, public, risk assessment Yes Yes No 100 requests/yr. Yes Fee Program - $100,000/ year Yes, grant application Yes, will consider Tees Yes California Air toxics, pollution prevention, ozone, public requests Yes Yes No 1210 requests over 4 years No Funds from hazardous waste program; all state funds Yes, consd. for Region Yes, will consider fees .5-1 Indiana Air toxics, health effects, inspections Yes Yes No 100 requests/yr. In 1987 Fed. grant for data use; no dedicated funding Yes, not top priority Yes, will consider fees 2+ equipment North Carolina Responds to public requests for Form Rs Yes No No 15-20 requests per year No State funds Yes Yes 4+ equipment Georgia Air toxics, permitting, compliance, emergency response Yes Yes No Yes Yes Fed. grant for 311, 312, added 313; no dedicated funding Yes Yes 3+ equipment Utah Air toxics, and other environ. programs, public requests Yes Yes No Yes Yes State funds Yes, will consider Yes No Kansas Reports, toxic loadings, air toxics, permits, public, risk assessment Yes Yes Yes 175 equests/yr. Yes State general funds, fees, grants Yes Yes 0-.5 Ohio Air toxics, permits, public, stream analysis Yes No No Yes Yes Fees, grant Yes No No Mary- land Inspections, permits, air-mgmL, 33/50 analysis, briefings Yes Yes No Yes No State funds Yes Yes Yes ------- Interviews were conducted with personnel in the following offices: BRS - Office of Solid Waste - Regional and state BRS contacts AIRS - Office of Air Quality Planning and Standards - Regional and state AIRS contacts This section outlines the results of those interviews, including recommendations to be taken into consideration if TRI adopts a state-based approach. 31 ------- Purpose/Description BRS, which is sponsored by the Office of Solid Waste, supports the Resource Conservation and Recovery Act program. Waste generators and waste treatment, storage, and disposal facilities must report every two years on what hazardous wastes they generated and how the wastes were managed. Handlers provide data to states or Regions, depending on how authority is delegated; all data entry is performed by the states and Regions. Public access to the BRS data is currently available through FOIA requests, and on NTIS tape. The data are used primarily by states to support their SARA Capacity Plans and by EPA to develop RCRA regulations and monitor the progress of the RCRA program. 32 ------- BRS Similarities to TRI: Generators are required to report what they have done in terms of pollution prevention Approximately the same number of reporting entities Some overlap between reporters; about 7,000 - 8,000 BRS handlers are also TRI reporters. 33 ------- Differences from TRI: RCRA is a state delegated program Data users are primarily internal to EPA and the states Original BRS legislation does not encompass all BRS data elements, including facility level data, and EPA has no actual authority to enforce submission of data not included in the draft rule. A final rule, however, is currently being promulgated. Data base cannot be accessed by the public on-line, and a national data base is not required by law Handlers report every two years, not every year In the past, there has been varying levels of management commitment to this program Data are electronically reported to the Regions from the states, and the data must pass basic quality edits to enable extraction of data oy Regions. Software for the states has non-mandatory edits for the states to perform. EPA performs Regional and Headquarters data quality checks once data are received. 34 ------- Difficulties Associated with Direct State Data Entry as Experienced by BRS: States and regional offices receive limited funding, so there is marginal incentive for states to participate States collect data for their own use, and therefore focus primarily on their own interests. States often collect and submit only data they use or data required by law. In the past, the data base was perceived as being a Headquarters data base and some Regions believed it is not of much use to them Data quality and consistency standards of state data are not at standards that are acceptable to Headquarters, and will require additional funding to improve. Significant resources are required to ensure acceptable data quality, but many states do not have enough resources Timeliness of data submission is a concern because data is often not submitted in a timely manner. 35 ------- Benefits Associated with Direct State Data Entry (vs. centralized) as Experienced by BRS: Data entry at the state level is accomplished quicker than at a Regional level if there is adequate funding This approach encourages states to have a stake in BRS. It improves a state's understanding of its hazardous waste material, and this understanding can be used in other program activities. States are more knowledgeable about certain facilities than EPA staff. 36 ------- Purpose/ Description AIRS is the national repository for information about airborne pollution in the U.S. It has four subsystems: Air Quality Subsystem (AQS); Air Facility Subsystem (AFS); Geo-Common Subsystem (GCS); and the Area/Mobile Source Subsystem (AMS) Interviews for this task focused on AFS because it was determined to be most relevant for TRI's purposes. AFS tracks emissions and compliance data from industrial plants. Emissions data is gathered from the facilities through surveys that each state (or local organization) develops Data entry approach differs by state; some states do direct online entry (approximately 20); others use their own systems to create a tape which is then converted; others submit manual reports to the Regional offices where the data are entered (limited); AIRS is updated nightly. 37 ------- Purpose/Description Coding conventions were established in the user's manual. States had to develop QA/QC plans for ozone data and have them approved by the Regional office. AIRS has automated edit checks and verification is performed on some data. Ongoing training is provided for Regions and states All states are funded to some extent by EPA grants (105 grants) EPA's National Computing Center provides connectivity to all states and free time share 38 ------- AIRS Similarities to TRI: AIRS has automated edit checks Some overlap exists in terms of air toxics. 39 ------- AIRS Differences to TRI: Air is a state-delegated program Regional offices are active with AIRS, assisting with quality assurance AIRS does not currently allow direct public access Data does not receive the same level of quality assurance as TRI data across all fields. Managers are extremely confident of the accuracy of some data and concerned about the accuracy of others. All data are not facility reported. Some data are measures of state activity with respect to inspections, enforcement actions, and therefore the states report the data themselves. States also estimate facility emissions and report the data. Some grant awards are based upon the level of activity that the states report to AIRS, so states have an incentive to participate Some data elements allow two entries, one for the federal and one for the state. 40 ------- ''"ilfci" %J^%S» "^ *. ><* ''j. Retrieval System _.vis_.j.__.j_ .£'... £ . . * X-. Benefits Associated with Direct State Data Entry (vs. centralized) as Experienced by AIRS: Data entry at the state level is accomplished quicker than it was with the Regional approach Fewer people handle the data creating less opportunities for error This approach encourages states to have a stake in AIRS States are more knowledgeable about certain facilities than EPA staff. 41 ------- Difficulties Associated with Direct State Data Entry as Experienced by AIRS: Difficulty in obtaining all necessary data elements Data conversion from tapes often introduces difficulties that require additional time to resolve Some states lack the resources to perform appropriate levels of QA Timeframe for entering data is not definitive; many states perform emissions data inventory entry as they are able. 42 ------- Recommendations: Must convince states that they have a vested interest in using the system; make system sufficiently flexible to serve state needs Demonstrate use of the state's data so that they will recognize the need for accurate, timely data Provide sufficient resources for personnel and equipment Need to consider the potential for integration between AIRS and TRI data and the implications of this Establish a state workgroup to negotiate approaches to state data entry 43 ------- 1 lll; :' :' ill! 'illll : The interviewee lists on the following pages are organized as follows: Headquarters Regional State System Managers. 44 ------- George Bonina, Office of Pollution Prevention and Toxics, Information Management Division, Deputy Director Ruby Boyd, Office of Pollution Prevention and Toxics, Information Management Division Sarah Hammond, Office of Pollution Prevention and Toxics, Environmental Assistance Division, State Liaison John Harmon, Office of Pollution Prevention and Toxics, Information Management Division Bob Janney, Office of Pollution Prevention and Toxics, Environmental Assistance Division, Regional Liaison Steve Newburg-Rinn, Office of Pollution Prevention and Toxics, Information Management Division, Public Data Branch Chief Janette Peterson, Office of Pollution Prevention and Toxics, Information Management Division 45 ------- Doug Sellers, Office of Pollution Prevention and Toxics, Information Management Division Sam Sasnett, Office of Pollution Prevention and Toxics, Economics and Technology Division Linda Travers, Office of Pollution Prevention and Toxics, Information Management Division Director Mike Walker, Office of Enforcement, Toxic Litigation Division Mike Wood, Office of Compliance Monitoring, Compliance Division Janet Bearden, Office of Compliance Monitoring, Policy Division Bridget Sullivan, Office of Compliance Monitoring, Policy Division 46 ------- Sylvia Bell, CBSI, TRI contractor Maxine Romo, CBSI, TRI contractor David Waggoner, CBSI, TRI contractor 47 ------- Helen Burke, Region IX, Pesticides and Toxics Branch Carlton Hailey, Region IV, 313 Coordinator, Pesticides and Toxics Branch Dennis Wesolowski, Region V, Pesticides and Toxic Substances Branch Warren Layne, Region VI, Pesticides and Toxics Branch Bob Hickland, Region VI, Enforcement ------- Steve Hanna, Chief, Office of Environmental Information, California Environmental Protection Agency Ken Rydbrink, Office of Environmental Information, California Environmental Protection Agency Fred Alvarez, Indiana Department of Environmental Management, MIS Robert Bierman, Indiana Department of Environmental Management, Office of Air Management, Sr. Environmental Manager Skip Powers, Indiana Department of Environmental Management, Emergency Response Branch, Staff Director Barty Titus, Indiana Department of Environmental Management, Office of Air Management, Director Bert Langley, Georgia Department of Natural Resources, Environmental Protection Division, Emergency Response Program Manager 49 ------- Carl Birns, Kansas Department of Health and Environment Cindy Sferra-DeWulf, Division of Air Pollution Control, Ohio EPA Marcia Mays, Toxic Registries Division, Maryland Department of Environment, Program Administrator Emily Kilpatrick, SARA Coordinator, North Carolina Department of Emergency Management Becky Kurka, Pollution Prevention and Conservation Division, Texas Water Commission Ken Zarker, Pollution Prevention and Conservation Division, Texas Water Commission Gena Guo, Pollution Prevention and Conservation Division, Texas Water Commission 50 ------- Bill Laxton, Technical Support Division, OAQPS Chuck Isbell, National Air Data Branch, OAQPS David Misenheimer, Emissions Inventory Branch, OAQPS David Mobley, Emissions Inventory Branch, OAQPS Ron Ryan, Emissions Inventory Branch, OAQPS Howard Wright, National Air Data Branch, OAQPS Jill Vitas, Alliance Technology, contractor to OAQPS George Czerniak, Region V, Chief Air Enforcement Branch Kathy Ferland, Texas Water Commission, BRS Joan Allen, Texas Water Commission, RCRIS George Murray, North Carolina 51 ------- \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY I WASHINGTON, D.C. ZQ46D or FCITIC1DCI ANO TOXIC SUBSTANCE SEP 22 1988 Re: Revised Policy for Acute Toxicity Testing Appended is a revised policy for evaluating the acute toxicity of chemical exposures under the Federal Insecticide, Fungicide and Rodenticide Act and the Toxic Substances Control Act. This action builds upon a previous revision of. the acute toxicity testing strategy to reduce the use of experimental animals while providing adequate information about chemical safety. The Environmental Protection Agency is disseminating this notice to industry, governmental bodies, scientific societies, animal welfare groups and interested parties to apprise them of our new position. The Agency's acute toxicity testing guidelines are being revised to reflect the positions.articulated in this policy. Victor Acting Assistant; Administrator for Pesticides and Toxic Substances Enclosure ------- Alternative Methodology for Acute Toxicity Testing The Environmental Protection Agency announces a revision to its approach to acute toxicity testing in fulfillment of actions under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Toxic Substances Control Act (TSCA). This revision reflects the Agency's concern about animal welfare and its continued efforts to reduce the impacts on animals of EPA's testing requirementsx While maintaining the tiered approach adopted in 1984, the Agency now recommends (when appropriate) the use of abbreviated test methods and consideration of using only one sex, as a means of reducing the numbers of animals in deriving important information on acute toxicity. Background EPA considers the evaluation of toxicity following short- term exposure to a chemical (i.e., acute toxicity) to be a limited but integral step in the assessment of the toxic potential of a chemical substance under the regulatory framework of its pesticide and toxic substances programs. The Agency also supports measures dedicated to reduce the use of animals in toxicity testing and conducts research on test methods which can lead to further reduction or elimination of animal usage and suffering. Through the careful selection of test methodology and maximization of the data obtained from acute studies, EPA strives to achieve a balance between the welfare of animals and the need to utilize animals in evaluating chemical safety. The approach to acute toxicity testing previously giver. in EPA's Test Guidelines (U.S. Env. Prot. Agency, 1978; 1979) emphasized the determination of the median lethal dose (LD50) with a 95% confidence interval. A 1984 update of the guidelines, ------- |