oEPA

TRI and CDR Data Use Examples

In addition to the toxic chemical management data collected through the TRI Program, EPA
collects information about the manufacture (including import) and use of chemicals in U.S.
commerce through the Chemical Data Reporting (CDR) rule implemented under TSCA.
Combining the chemical information reported to both TRI and CDR provides a more complete
picture of a chemical's lifecycle from sources of import and domestic manufacture to final
deposition in the environment or products.

The TRI National Analysis reports from 2016, 2015, and 2012 included feature sections
illustrating how CDR data complements TRI information. Those sections, as originally published,
are presented here. For more information on the CDR program, see www.epa.gov/cdr.
Additional guidance for using TRI data can be found on the www.epa.gov/toxics-release-
inventory-tri-program/find-understand-and-use-tri.


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TRI and CDR - Example #1

For calendar year 2015 activities, 8,707 individual chemicals were reported to the CDR, which
tracks production and imports. 499 individual chemicals and chemical categories were reported
to TRI. Of the chemicals reported to TRI, 250 (50%) were also reported to CDR. The remaining
249 chemicals reported to TRI are either not subject to Chemical Data Reporting under TSCA
(such as pesticides, pharmaceuticals, polymers, and TRI-specific chemical categories); the facility
is exempt from CDR reporting based on business size thresholds; the chemicals are produced in
amounts below the CDR reporting thresholds; or the chemicals are processed or used by
facilities that report to TRI, but not manufactured or imported, which are the activities required
to be reported to CDR.

To illustrate how TRI information complements the TSCA chemical assessments, one chemical, 1-
bromopropane (1-BP), is presented as an example.

MANUFACTURE AND IMPORT

Volume Used: 25.9 Million Pounds*

138-393 CDR sites

CDR Industrial Processing and Use Scenarios:

•	Use as an Intermediate

•	Processing into formulations

•	Processing into articles

•	Non-incorporative industrial Uses

•	Repackaging

COMMERCIAL AND CONSUMER USES

1 Cleaning and furnishing care products
1 Adhesives and sealants
1 Electrical and electronic products



n

Recycled

Used for Energy Recovery

Treated

Released

1 91% 9%

322,000 Pounds

On-site

Off-site



68%

m

326.000 Pounds

On-site

Off-site



471



114,000 Pounds

Air

Land Off-site

78%

800,000 Pounds



Water

<1%



TRI does not collect data
on on commercial- and
consumer-related wastes

* Production volume based on value from EPA's 2017 Scope of the
Risk Evaluation for 1-Bromopropane

In 2015, 10 manufacturers, including importers, reported a total production volume of 25.9
million pounds of 1-BP manufactured/imported. Industrial activities reported included use as an
intermediate in chemical manufacturing, processing into chemical product formulations (e.g.,
solvents for cleaning and degreasing and adhesives), processing into articles (e.g., insulation),
non-incorporative uses (e.g., solvent degreasing), and repackaging.

Commercial and consumer uses reported included adhesives and sealants, cleaning and
furnishing care products, and electrical and electronic products. In 2016 (the first year 1-BP was
a TRI-listed chemical), 55 facilities filed a TRI form for 1-BP, reporting a total of 1.56 million
pounds of waste, most of which (51%) was released.

2016 TRI National Analysis was published in January 2018. Example of CDR/TRI mashup for 1-bromopropane (1-BP).


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TRI and CDR - Example #2

To illustrate how TRI information complements the TSCA chemical assessments, one chemical,
trichloroethylene (THE), is presented as an example.

EPA has undertaken efforts to reduce the risks TCE poses to public health and the environment.
For example, EPA has conducted a risk assessment; initiated a rulemaking to eliminate the risk of
TCE in aerosol degreasers, as a
spotting agent at dry cleaning
facilities, and in vapor degreasing
operations; and coordinated a
voluntary phase out of TCE in arts
and crafts spray fixative product
marketed to consumers.

Utilizing the chemical information
reported to TRI and collected under
the CDR rule together provides a
more complete picture of a
chemical's lifecycle from sources of
import and domestic manufacture to
means of final disposition in the
environment or products, as shown
in this figure.

In 2011, nine manufacturers,
including importers, reported a total
production volume of 225 million
pounds of TCE manufactured.

Industrial uses reported include as a
solvent or intermediate in chemical manufacturing. During the same year, 227 facilities filed a
TRI form for TCE, reporting a total of 90 million pounds of waste, most of which (87%) was
managed through recycling.

2015 TRI National Analysis was published in January 2017. Example of CDR/TRI mashup for trichloroethylene (TCE).

Trichloroethylene (TCE) Production Volume:
225 million lb

Exposure to TCE is associated with the potential to cause
cancer, impact a developing fetus, and affect the liver,
kidneys, immune system, and central nervous system.

Reported by 9 facilities (CDR)

Reported by 227 facilities (TRI)

Industrial Uses:

•	Solvents (for cleaning and degreasing)

•	Agricultural chemicals (non-pesticidal)

•	Intermediates

•	Functional fluids (closed systems)

•	Solvents (which become part of a
product formulation or mixture)





Commercial and Consumer Uses:

Adhesives and sealants

Intended for Children's Use:

None listed

TCE Waste Managed:
90.2 million lb

2.1 million lb
used for energy
recovery

2 8 million lb
released


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TRI Releases of Trichloroethylene

The figure below shows the trend in releases of trichloroethylene (TCE) reported to the Toxics
Release Inventory (TRI) over the last ten years.

As shown in the figure, since 2005, releases of TCE reported to TRI have decreased by 66%.
Much of the reduction is from decreased releases by the Fabricated Metals sector, which uses
TCE in degreasing. EPA's TRI Pollution Prevention (P2) Spotlight provides additional information
on how this sector is reducing their TCE releases. The number of facilities reporting TCE also
declined considerably during this time.

TRI reporting facilities also provide
information on the source
reduction activities they
implement to generate less waste.
From 2011 through 2015, 28% of
the facilities reporting TCE
reported a source reduction
activity; among the most common
are:

•	cleaning and degreasing
modifications, such as changing to
aqueous cleaners, and

•	process modifications, such as
upgrading valves or adding
insulation to a degreaser to
reduce TCE use and losses.

Use the TRI P2 Search Tool to view
descriptions of facilities' activities
to reduce TCE wastes. For example, an aircraft component manufacturer replaced the existing
steam control valve on its TCE vapor degreaser with an electronically controlled steam valve. This
change enabled them to run more parts through the degreaser while reducing TCE consumption.

2015 TRI National Analysis was published in January 2017. Example of CDR/TRI mashup for trichloroethylene (TCE).

Releases for Trichloroethylene

400

300

100

Year

Click on legend items below to customize items displayed in the chart
H Disposed of or Otherwise Released ~+- Reporting Facilities


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TRI and CDR - Example #3

For calendar year 2011 activities, 7,674 individual chemicals were reported to CDR and 514
individual chemicals and chemical categories were reported to TRI. Of the chemicals reported to
TRI, 273 (53%) matched one or more CDR chemicals while the remaining 241 were not reported
to CDR. Most of these 241 chemicals are not regulated by TSCA (such as pesticides,
pharmaceuticals, and polymers), and thus are not required to be reported to CDR. In some cases,
CDR data, including chemical identity, are withheld as confidential business information and,
therefore, this analysis may underestimate the actual overlap between the two programs.

CDR complements TRI information, tracking the
quantity of chemicals domestically
manufactured and imported, and the known
uses of chemicals in industrial processing and
in consumer and commercial products. CDR
reporters indicate if the product is "intended
for use by children," which means the
reported chemical or mixture is used in or on
a product that is specifically intended for use
by children 14 or younger.

Uses of CDR Matched with TRI Chemicals and
Chemical Categories

Industrial and
Commercial or
Consumer Uses
Reported (169}

Intended for
Children's
Products (22)

The figure to the right shows how reported

TRI chemicals correlate with CDR reported uses. Nearly all chemicals (259) had industrial uses
and 169 also had commercial or consumer uses.* Of the chemicals with commercial or consumer
uses reported, 22 were in products intended for use by children.

TRI and CDR Data for Ethylbenzene

Ethylbenzene is used as an example of how TRI and CDR data for 2011 may be combined for a
more complete picture of the chemical's lifecycle. Ethylbenzene is reportable under both
programs and used in consumer and commercial products intended for use by children.

Exposure to ethylbenzene is associated with health effects including irritation of eyes, skin, and
respiratory track while chronic exposure may be associated with renal cancer or other cancers,
as well as damage to hearing or the inner ear.

Ethylbenzene is a natural constituent of crude oil and is present in many petrochemical products
and fuels; however, most industrial grade ethylbenzene is produced by the reaction of benzene
and ethylene. In 2011, 31 facilities reported to CDR a total production volume of 9.66 billion
pounds of ethylbenzene manufactured (which includes quantities imported). For activities during
the same timeframe, 1,315 facilities filed a TRI form for ethylbenzene.

* Industrial uses are reported for chemicals meeting the more than 100,000 pounds CDR manufacturing threshold. Therefore, if a chemical is
manufactured in small amounts, it would not be reported.


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The figure below combines 2011 CDR and TRI data for ethylbenzene to show its production,
uses, and waste management. The 31 CDR filers reported downstream industrial uses and
consumer and commercial uses, including five products intended for children's use. The CDR
filers also indicated the industrial sectors that use ethylbenzene, including:

•	Paint and Coating Manufacturing

•	Basic Organic Chemical Manufactur

•	Plastics Material and Resin
Manufacturing

•	Petroleum Refineries

•	Petrochemical Manufacturing

Many of the 1,315 TRI facilities reporting
ethylbenzene were also in these sectors.

The TRI facilities reported managing 78.4
million pounds of ethylbenzene as waste,
which represents less than 1% of the total
production volume reported to CDR,
indicating that the chemical was largely
consumed in a process or is in a product,
rather than ending up as a waste. This is
further supported by the CDR data that
show the two top industrial functions for t
chemical are intermediates and solvents.

Almost half of the ethylbenzene waste wa
used for energy recovery, and 5% (3.7 mill
pounds) was disposed of or otherwise released primarily as air emissions or through
underground injection.

TRI reporters also provide information on source reduction activities implemented to generate
less waste. Of the 1,315 TRI facilities reporting for ethylbenzene, 121 (9%) reported a source
reduction activity; among the most common are:

•	Improved maintenance scheduling, recordkeeping, or procedures

•	Changed production schedule to minimize equipment and feedstock changeovers

•	Substituted raw materials

One facility with large reductions in ethylbenzene air emissions from 2010 to 2011 reported
installing a thermal oxidizer to destroy emissions from their coating line.

2012 TRI National Analysis was published in February 2014. Example of CDR/TRI rnashup for ethylbenzene.

ing

:h is

s

I i r\ n

Ethylbenzene Production Volume:
9,660 million lb

+ ^

Industrial Uses Include:

Intermediates; fuels and additives;
solvents and processing aids;
paint and coating additives;
adhesives and sealants

Commercial and Consumer
Uses Include;

Paints and coatings; fuels;
building/construction materials;
electrical and electronic products;
lawn and garden care products

Intended for Children's Use:

Toys, playground, sporting
equipment; food packaging;
arts, crafts, and hobby materials;
furniture and furnishings;
plastic and rubber products

Ethylbenzene Waste Managed:

78.4 million lb

121 Source Reduction Activities Reported

38.3 million lb



used for



energy recovery I



V

I 16.1 million lb

^1

_



L 3.7 million lb



disposed of or



otherwise released

Reported to CDR by 31 facilities

Reported to TRI by 1,315 facilities


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