Important Information You'll Want to Know

                                   What is TRI?
                                Who Reports to TRI?
                                  Who Uses TRI?
                              How Does TRI Affect Me?
                          Factors to Consider When Using TRI
United States
Environmental Protection
Agency

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                                      What is TRI?
  Background

  In 1984, a lethal gas leaked from a Union Carbide pesticide plant in Bhopal,
  India, causing the deaths of nearly 6,500 people. Nine months later, a similar
  plant in West Virginia had a potentially dangerous release of a toxic pesticide.
  No lives were lost, but it was clear that toxic chemical releases, both routine
  and accidental, could endanger public health. In response to this threat,
  Congress passed the Emergency Planning and Community Right-to-Know
  Act (EPCRA).
                                                                            Each year over
                                                                            95,000 reports
                                                                             representing
                                                                          billions of pounds
                                                                             of chemical
                                                                             releases are
                                                                           submitted to EPA by
                                                                             more than 25,000
                                                                                 facilities.
Hailed as one of the strongest environmental laws passed in the 1980's, the
Right-to-Know Act's primary purpose is to inform communities and citizens of
chemical hazards.  The law was written with ordinary people in mind, and
was based on the principle that the more people know, the more effective
they can be in improving local health and safety. The law requires
businesses to report the locations and quantities of chemicals stored on site,
and helps communities prepare for chemical spills and similar emergencies. It
also requires certain facilities to report releases to the environment of over 650 toxic chemicals and chemical
categories. This information is collected into a national and publicly available database... the Toxics Release
Inventory (TRI).

TRI is unique in that it marks the first time that the public has direct access to detailed information about
releases and management of toxic chemicals in their communities. With information from TRI, citizens can
increase their knowledge of chemical releases in their area and use this knowledge to affect community
environmental policy and change.


TRI Information

The TRI database includes information on:

V     What chemicals were released into the local environment since 1988;
V     How much of each chemical went into the air, water and land;
V     How much of the chemicals were transported away from the reporting facility for disposal, treatment,
      recycling or energy recovery; and
V     How chemical wastes were treated, disposed, recycled, or burnt for recovery at the reporting facility.

TRI is a  public "report card" for the industrial community, creating a powerful motivation for waste reduction.
This annual accounting of the nation's management of industrial toxic chemical wastes is a valuable source of
information for concerned individuals and communities. Citizens can use TRI to evaluate local facilities
through  comparisons, determine how toxic chemicals are used, and with other information, identify and
evaluate potential health risks to their community.  Organizations can use TRI information as a starting point
for constructive dialogue with facilities in their area.
United States
Environmental Protection
Agency
                                                                                     EPA 908-F-04-001P
                                                                                     August 2004

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                            Who Reports to TRI?
Reporting Requirements

A facility is required to report if it:

  1.    Has ten or more full-time employees (or the
       equivalent of 20,000 work hours per year);

  2.    Manufactures, imports, or processes over
       25,000 pounds or uses more than 10,000
       pounds of one of the approximately 650
       designated chemicals or the 28 chemical
       categories specified in TRI;  and/or

  3.    Manufactures, imports, processes or uses
       any Persistent, Bioaccumulative and Toxic
       (PBT) chemical above the specified chemical
       threshold during the reporting year.  PBT
       chemical thresholds range from 0.1 gram to
       100 pounds; and

  4.    Conducts operations as specified by the
       Standard Industrial Classification (SIC)
       Codes... as listed to the right.
                                                     Standard Industrial Classification (SIC) Codes
                                                                    by Industry

                                                   10     Metal Mining (excluding 1011,1081,1094)
                                                   12     Coal Mining (excluding 1241)
                                                   20     Food
                                                   21     Tobacco
                                                   22     Textiles
                                                   23     Apparel
                                                   24     Lumber and Wood
                                                   25     Furniture
                                                   26     Paper
                                                   27     Printing and Publishing
                                                   28     Chemicals
                                                   29     Petroleum and Coal
                                                   30     Rubber and Plastics
                                                   31     Leather
                                                   32     Stone, Clay and Glass
                                                   33     Primary Metals
                                                   34     Fabricated Metals
                                                   35     Machinery (excluding electrical)
                                                   36     Electrical and Electronic Equipment
                                                   37     Transportation Equipment
                                                   38     Instruments
                                                   39     Miscellaneous Manufacturing
TRI provides the first comprehensive overview of        49     Electric utilities (including 4911,4931,4939)
toxic chemical pollution from manufacturing facilities      4953   Commercial Hazardous Waste Treatment
in the United States; however, reporting                ;|169   Chemicals and Allied Products; - Wholesale
                        ...     , .                   5171   Petroleum BulkTermmals and Plants
requirements do not cover aN industries that release      738Q   So|vent Re      Servjces
toxic chemicals. Also, the law does not cover toxic
chemicals that reach the environment from non-
industrial sources such as automobiles. Reported
releases are estimates and there is no way to discern whether a chemical has been released in a single large
burst or routinely throughout the year. Though the TRI database does offer information on the health effects of
a specific chemical, the user cannot ascertain levels of exposure or risk without combining TRI information with
information from other sources. Although the TRI reporting base has its limitations, it  provides communities
with a springboard from which citizens can seek further vital information about toxic chemicals in their area.

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                                    Who uses TRI?
  The TRI is a rich source of data originally intended for concerned citizens who, on their own or through orga-
  nized groups, use TRI to raise and answer questions about chemical releases in their communities. Today, TRI
  has a broad-based audience that includes manufacturers, environmental consulting firms, trade associations,
  labor groups, health professionals, state and local environmental agencies, Local Emergency Planning Commit-
  tees (LEPCs), and federal agencies. Whether the TRI is used to influence local government action, emergency
  planning, the education of citizens, or to spur industry-citizen cooperation, it is clear that it plays a vital role in
  enhancing nationwide efforts to improve our nation's precious environment.
  CITIZENS. The Emergency Planning and Community Right-to-Know Act (EPCRA) was written on the principle
  that the more citizens know, the more effective they can be in avoiding chemical hazards in their communities.
  TRI enables citizens to become more aware of toxic chemicals in their own neighborhoods. It encourages
  dialogue between individuals and local companies which can result in a change in current practices and im-
  prove local environment. For example, a group of Minnesota residents used TRI data to encourage a local
  facility to reduce the use of a carcinogen by 90 percent. One neighborhood near Houston, Texas, worked
  directly with a local plant to develop an emissions reduction plan, using recent TRI data as the basis for discus-
  sions.  Citizens often use the TRI data in combination with other information sources to determine health-
  related risks in their community.


  BUSINESSES.  Businesses can use the TRI data as a basis for reducing large stocks of toxic chemicals
  located in dense population areas or to lower levels of chemical releases. TRI data is also used to cut costs
  and improve operations. "Wastes" represent an expense - an estimated $100 billion + is spent in producing the
  toxic wastes in TRI alone.  Companies are using TRI to increase awareness of environmental business oppor-
  tunities and, as a result, reduce the use of toxic chemicals.  TRI is also used to market chemicals or pro-
  cesses that are cleaner, safer, or more cost-effective for the reporting facilities.  Law firms, real estate com-
  panies, insurance firms, and banks use TRI to identify potential liability issues associated with a particular
  parcel of land or facility. Most important of all, the publicity that has resulted from the availability of TRI data
  has caused many companies to voluntarily reduce toxic chemical releases.


  FEDERAL AGENCIES. TRI data is used extensively at the federal level for a variety of programs.  Congress
  relies on TRI to prepare environmental legislation. The Agency for Toxic Substances and Disease  Registry, a
  federal public health agency whose job it is to prevent or minimize adverse health effects from exposure to
  hazardous substances, uses TRI data to set goals for improving the nation's health. The Internal Revenue
  Service uses TRI data to measure the compliance of reporting companies with tax laws pertaining to the use of
  toxic substances.
United States
Environmental Protection
Agency

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EDUCATIONAL INSTITUTIONS. Academic researchers rely heavily on TRI data to conduct critical studies
of the environment. Several universities use TRI reports to study how chemicals are used and develop
alternative technologies for the prevention of toxic releases.


PUBLIC INTEREST GROUPS.  Public interest groups make effective use of the TRI data by challenging
facilities to educate citizens. Most often, they use TRI to bring public sentiment to bear on facilities and public
officials. For example, the Silicon Valley Toxics Coalition used TRI to identify companies emitting potentially
harmful chemicals, and urged them to cut releases.  One official from a well-known company was quoted as
saying that the "right to know" was a "significant factor" in the decision to significantly reduce their chemical
releases. National public interest groups often publish reports based on the TRI data. For example, a study
highlighting the nation's toxic polluters and a report naming companies releasing known ozone-depleting
chemicals were developed as a result of the availability of the TRI data. The TRI is also vital for presenting a
convincing case to influence legislators. The Massachusetts Public Interest Research Group figured
prominently in the passage of the nation's first state toxics-use reduction law, and many other states have
followed suit.
LABOR ORGANIZATIONS. Concern for worker safety was a key factor in the original passage of the
national right-to-know legislation. The right to know about chemical  hazards in the workplace has been a
consistent goal of organized labor since the early 1970s.  The Amalgamated Clothing and Textile Workers
Union teamed up with a Minnesota community and used the TRI data to campaign for a reduction in the use
of methylene chloride, a known health hazard to the workers, and to search for safer alternatives.  Union
members and activist pressured the state for tougher regulations that would force the company to cut
emissions by 93 percent.  One worker remarked, "Right-to-Know" provided the catalyst.  Once the
community got involved, there was a tremendous pressure  on the business to reduce the risks!"  Publication
of toxic release data often causes companies to improve environmental performance.


STATE AND LOCAL AGENCIES. TRI data is vital to hospitals, schools, and state and local governments for
emergency planning and response at the state and local level. Many Emergency Management Agencies, fire
departments, and Emergency Medical Services use TRI to identify chemicals  in use and map facility layouts
for more effective, quicker response to emergencies. The TRI data  is also used to identify the need for, the
introduction and passage of state and local legislation.
HEALTH OFFICIALS.  TRI data can be used to build an information base on hazardous chemicals used,
manufactured, or transported in a state or community.  Health professionals can use this information to
prepare personnel for emergencies.  TRI is used to help diagnose, treat or study health effects resulting from
chemical exposure in the community or workplace.

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                          How Does TRI Affect Me?
  A Matter of Risk

  V      What are these chemicals and how toxic are they?
  V      What other chemicals are made or stored at this facility?
  V      Will these chemicals affect my health?
  V      What is the government doing about these releases?
  V      How do I find out what's going on in my community?

  These are not easy questions to answer. Many factors must be considered in order to evaluate what risks, if
  any, you face from the presence of toxic chemicals in your local environment.  Risk is the measure of the
  chance that you will experience health problems or the environment will be degraded. Risk screening uses
  available information, such as TRI, to develop a relative estimate of risk for a given set of conditions.  Risks
  are ranked as high, medium, or low in order to set priorities for further evaluation.
  Risk Screening

  TRI data is a first link to discovering
  which chemicals being manufactured,
  released, or transferred in your commu-
  nity pose a threat to human health and
  the environment. TRI will tell you the
  names and estimated amounts of
  chemicals released in your area during
  the preceding year. You can also find
  out about chemicals that were trans-
  ferred into or away from your area for
  treatment and disposal. This informa-
  tion alone does not indicate the risks
  that these chemicals pose or may pose
  to human health and the environment.
  Small releases of highly toxic chemicals
  may be a greater risk than very large
  releases of less toxic chemicals.
  Though TRI data is useful to evaluate
  the risk in your community, other infor-
  mation is required to form a complete
  picture. A determination  of risk de-
  pends on the release conditions, extent
  of exposure, environmental conditions,
  and other factors.
United States
Environmental Protection
Agency
Ranking the Potency of the Chemical

The toxicological potency of a chemical is a measure of a chemical's
potential harm to human health and the environment. Health effects
include the potential to cause cancer, genetic damage, reproductive
damage, or harm to the nervous system. Environmental effects
incorporate potential for damage to plants, animals, and fish.

Ranking the Exposure of the Chemical

Regardless of how toxic a chemical is, it cannot do harm unless it
has contact with the environment or a human being. In ranking
exposure, you must first look at the amount of the chemical that is
being released, the duration and intensity of the release, and how
long the chemical remains in the environment.  Then it is important to
define the route of the exposure. Is the chemical moving through the
air, surface water, or ground water? Finally, the exposed population
must be defined, as the more people exposed the higherthe likeli-
hood that health problems will occur.

Ranking the Potential Risk of the Chemical

Using the potency and the exposure ratings, risk screening identifies
the chemicals, facilities, and routes of exposure that present a "high",
"medium" or "low" priority for a follow-up investigation. This final step
establishes the probability that a release in a particular area will harm
human health orthe  environment.

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What You Can Do to Learn More About Risk
Once you become aware of toxic chemical releases in your community, you can decide what to do next.
Here are several ideas...

LEARN THE FACTS.  In addition to chemical release information, TRI contains the names and phone
numbers of public contacts at reporting facilities. Companies are becoming more sensitive to citizens'
concerns about health and the environment, and some have begun community outreach programs.
Company officials may provide answers to your questions that could affect risk screening. They can also
steer you toward local agencies, for example, the Local  Emergency Planning Committee (LEPC).

GO TO YOUR LOCAL LIBRARY. Ask your librarian to help you find information about chemicals in your
community. There are several standard reference works that can help you decide whether further
investigation is warranted.

IDENTIFY YOUR LOCAL SAFETY AND HEALTH AGENCIES. These groups can help you evaluate what
you have learned and identify any additional information  you may need.  Most counties have a public health
agency staffed by one or more doctors, including a county health officer. Some areas have poison control
centers with toxicologists and other staff who may be of  some assistance.  If you have difficulty identifying
appropriate agencies in your area, call the local hospital  or fire department for a referral.

LOCATE YOUR LOCAL EMERGENCY PLANNING COMMITTEE.  The Emergency  Planning and
Community Right to Know Act (EPCRA) which created TRI also established Local Emergency Planning
Committees (LEPCs) to plan for emergency action in the event of hazardous chemical spills and  similar
incidents.  LEPCs are aware of hazardous chemicals used and stored by facilities in your area. They receive
Material Safety Data Sheets that detail physical properties and health effects of hazardous chemicals used by
local manufacturers and other facilities. LEPCs, while often associated with existing county-level  emergency
planning and civil defense agencies, include representatives of environmental and transportation agencies,
fire fighters, hospitals, the media, community groups,  and others.

CALL THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR). ATSDR is the
leading federal public health agency concerned with risks resulting from chemical  exposure.  ATSDR makes
information on the health effects of hazardous substances available to the public, conducts health
assessments, and  sponsors research.

NETWORK WITH NEIGHBORS AND COMMUNITY GROUPS. This is a good way to exchange
information, participate in meetings with officials, experts, and company representatives, and plan activities
that address your concerns. The  more people that are involved, the more attention you are likely to receive
from industry officials, government agencies, and the news media.

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              Factors  to Consider When  Using TRI
  TRI data, in conjunction with other information, can be used as a starting point in evaluating exposures that
  may result from releases and other waste management activities which involve toxic chemicals. The
  determination of potential risk depends upon many factors, including the toxicity of the chemical, the fate of the
  chemical, and the amount and duration of human or other exposure to the chemical after it is released. Listed
  below are some of the factors that should be considered when reviewing TRI data.
  Toxicity of the Chemical

  •     The TRI list consists of chemicals that vary in their ability to produce toxic effects. Some high-
        volume releases of less toxic chemicals may appear to be a more serious problem than lower-volume
        releases of more toxic chemicals, when just the opposite may be true.


  Exposure  Considerations

  •     Potential degradation or persistence of the chemical in the environment. Exposure to a
        chemical is dependent upon the chemical being available in the environment.

  •     Bioconcentration of the chemical in the food chain. As a chemical becomes incorporated in the
        food chain, it may concentrate or disperse as it moves up the food chain.

  •     The environmental medium (air, water, land, or underground injection) to which the toxic
        chemical is released. Chemical exposure of a population depends on the environmental medium to
        which a chemical is released.

  •     The type of off-site facility receiving the chemical and the efficiency of its waste management
        practices. The amount of a toxic chemical that ultimately enters the environment depends on how the
        chemical was handled during treatment, energy recovery or recycling activities.

  •     On-site waste management of the toxic chemical. As with off-site waste management, the amount
        of the toxic chemical released to the environment depends on how the chemical was handled during
        treatment, energy recovery or recycling activities.
United States
Environmental Protection
Agency

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Limitations of TRI  Data

While TRI provides federal, state and local governments, the public, and industry with key environmental data,
it has some limitations that must be considered:

      TRI data reflect releases and other waste management of chemicals, not exposures of the public to
      those chemicals.
      Although the EPA has expanded the TRI program, it does not cover all sources of releases and other
      waste management activities such as automobile emissions, nor does it cover all toxic chemicals or
      industry sectors.

Beyond reporting releases and waste management activities, only limited and very general information on
chemical storage is provided. In addition, while many facilities base their TRI data on monitoring data, other
facilities report estimated data to TRI as the program does not mandate chemical release monitoring.

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