In the October 4, 2005 Federal Register, the EPA noted that it wants to make changes to the Toxic Release Inventory Reporting Program. As summarized by Greenwatch, the EPA has proposed three changes in TRI reporting: Move from the current annual reporting to every other year reporting for all facilities, essentially eliminating half of the TRI program. Allow companies to release 10 times as much pollution (raising the reporting threshold from 500 pounds to 5,000 pounds) before requiring them to report on how much pollution was produced and where it went. Allow facilities to withhold information on low-level production of persistent bioaccumulative toxins (PBTs), including lead and mercury, which are dangerous even in very small quantities because they are toxic, persist in the environment, and build up in people's bodies.
Senator Jim Jeffords, I-Vt, the ranking member of the Senate Environment and Public Works Committee, issued a blunt and direct statement to the EPA regarding its proposals. To say the least, Senator Jeffords is not happy with the proposal. Other Senators including John McCain (R-Az) have joined him and sent the EPA Administrator a letter expressing "…serious concerns about…recently announced proposal to weaken the…Toxic Release Inventory (TRI) program. The chemical industry is probably the industry most burdened by TRI reporting. In a Chemical & Engineering News article, "A Smaller Right-to-Know?," Cheryl Hogue reports that "many in industry, including two major chemical manufacturing trade groups, are backing the planned changes.
“The overall burden of the system has dramatically increased” over the years, says Michael P. Walls, managing director of the American Chemistry Council. He says ACC is “very encouraged by EPA's announcement” on TRI. For years, the industry group has urged the agency to reduce industry's burden of reporting TRI information while maintaining the quality of this database, he adds. “Reforming and streamlining reporting requirements and other regulatory burdens is critical if we want to balance the public's right-to-know with the need for chemical manufacturers to have the resources necessary to compete in the global market,” says Joseph Acker, president of the Synthetic Organic Chemical Manufacturers Association." Overall, the TRI reporting program has been a catalyst for improved accounting and transparency of the emissions of "toxic" chemical emissions. The benefits of the program have been a reduction in the amount toxics released to the environment, the standardization of methods for calculating emissions, and education of the general public about the type, amount, location, and location of toxics released by the industry. Most environmentalists, regulators, and regulated companies will admit (although perhaps not publicly) the program has been successful. The program has been in place since 1987 and regulated companies have adapted to the effort and burden of reporting. Moreover, the public is accustomed to receiving annual updates of toxic release. Why mess with a winner? I suspect it’s a blend of politics and the effects of globalization. I'm not going to touch the former. With regards to the latter, many companies would love to reallocate resources from regulatory reporting to R&D, sales and marketing, or supply chain. The low margin industries in particular are under constant attack by low cost overseas producers. Any savings or increase in productivity could mean the difference between profit and loss. Personally, I think this is another example of how technologically behind the times EPA, industry, and environmental reporting is in the United States. We have productivity tools for accounting, supply chain, maintenance, etc. Companies have spent billions of dollars since the early 1990's increasing productivity through information technology. Similar tools exist for TRI reporting. These tools go beyond what EPA discusses in its Federal Register proposal for reporting the numbers. These tools can help companies gather daily information about air, water, and waste emissions, and with the push of a button totalize emissions data on a daily, weekly, monthly, quarterly, semi-annual, or annual basis. With another push of a button, these tools can extract the information from a central database to the EPA TRY-ME reporting files from where they can be electronically submitted to EPA. If companies spent a few dollars on the proper productivity tools for environmental engineers and scientists, perhaps we wouldn't even be having the above debate. by
Doug Hatler, CHMM
DHatler@enviance.com |
