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I'd like to open my remarks by affirming our conviction that our primary goal is to reduce and in some cases eliminate production, use of, and exposure to toxic substances. Toxic substances are poisoning us and companies have a responsibility to let us know what dangers we may be facing.
Much of the recent work of our office has been framed within the context of working for implementation of the Great Lakes Water Quality Agreement. Of particular concern to us are the class of toxic substances which are persistent and bioaccumulate. Mercury, dioxin and PCB's are examples of such toxins. We are encouraged by your strategy of empowering pollution prevention initiatives by providing information and support to the public. TRI as it now stands could be improved to provide even further encouragement of pollution prevention and to allow thorough assessment of pollution prevention gains at any given facility.
We see materials accounting data as a significant enhancement to the current TRI. This also is important as a national level program. The information that can become available through materials accounting would be a crucial tool for those people who currently suffer the disproportionate impacts of our modern chemical society. There of course would be a need make this information as accessible as possible.
One example of an existing program is the Michigan Critical Materials Registry. This registry includes over 100 chemicals and requires use of any amount over 1 lb of a listed substance be reported. Lower thresholds for reporting such as in this case are an important element to be included in any chemical use inventory. The definition of use here includes chemicals, "manufactured, stored, discharged in wastewater, disposed of as other waste materials (residuals), or otherwise present either alone or as components of other host materials which are present as a result of your business activity." Information from this registry was a critical part of the research conducted by U.S. EPA's Great Lakes National Program Office as part of their work to virtually eliminate persistent toxic substances from the Great Lakes Basin. Information on mercury and PCB's obtained from the Michigan Critical Materials Registry were a significant part of the background material for last weeks' meeting of EPA's Virtual Elimination Pilot Project. The registry showed a total of 273 facilities reported mercury useage in 1991. The same data base showed that a total of 360 facilities reported using over 12 million lbs. of PCB's in 1991. This is an excellent example of how national, state and eco-system based projects can benefit from accurate and complete information.
As a participant in earlier meetings with EPA on this issue, you should have on record that we are supportive of including all six basic calendar year throughput measures into any materials accounting requirements. We also, favor tracking substitution and the inclusion of occupational demographics data.
In closing, I'd simply like to echo the sentiments of the many today who have urged you to make implementation of a thorough chemical use inventory which includes facility level reporting, among the highest priority issues of your office.
Source: RTK Net, Washington DC
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