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Comments from the Chesapeake Bay Foundation
on the proposed Chemical Use Inventory


28 September 1994
Contact: Jacqueline Savitz

The EPA issue paper, revised 2 September 1994, makes an excellent case for the values of submission of chemical use data in a manner similar to that of the Toxics Release Inventory Data. One inherent difference and benefit of chemical use data is that quantities will not depend on estimation techniques, and can be acquired, as EPA pointed out through inventory and invoicing mechanisms. A number of the potential values of MA data, which EPA points out, are strongly dependent on facility-by-facility reporting. Aggregated data will serve little purpose for directing emergency planning efforts, minimizing occupational safety risks, and providing communities the "Right-to-Know" about chemical flow through their areas. Therefore, we strongly suggest that the data be made available in a non-aggregated format.

All the examples given in the issue paper are valid, and we will not reiterate them. Rather I will try to give some specific examples to help demonstrate some of them, and to point out others. For the purposes of completeness, I have listed at the end issues that are critical, but did not require further discussion.

First, one value of the materials accounting approach that was not discussed in detail is the value to the company. As was pointed out, the TRI data served a valuable purpose to companies since the information had not been previously collected. As a result it informed and directed corporate efforts. Use data will do the same thing. In many instances, companies have not looked closely at chemical use overall. This is especially important where a given company has multiple processes ongoing, and a number of shops that do not have centralized materials management. The Naval Aviation Depot in Jacksonville Florida was such a "company". They had five process shops that all separately ordered chemicals from four suppliers. Each shop determined its own level of stock, and each shop had its own waste disposal and HAZMAT system. Excessive HAZMAT stocks led to expiration of chemicals shelf lives, and wasted chemicals. Often bulk "drums" were ordered when only "pints" were needed. This process also required excessive training and oversight.

By establishing an environmental control center, centralizing the ordering and dispensing of chemicals, the HAZMAT program and the waste disposal programs, the Depot reduced its hazardous waste generation by 72,000 pounds, and increased recycling 200%. Hazardous material stocks were reduced by 75%. To determine whether or not this represents a reduction in use of chemicals, we would need CUI data. Luckily, in this case, the Navy reports that this translated into a $2.27 million reduction in procurement of hazardous chemicals which suggests that use actually was reduced. This example clearly demonstrates the value of chemical use reporting to the actual companies. It does not demonstrate that companies will do this accounting voluntarily. When we asked the Navy why they embarked on this project, the simple answer was... "They made us." Referring to the Presidents Executive Order on Federal Agency Pollution Prevention. It does take a mandatory reporting program to motivate companies to embark on programs, even if they have cost-saving potential.

One useful outcome of MA data reporting may also be that companies join together to manage their hazardous materials acquisition and/or storage.

This program has other components, and is an excellent example of an in-place use reduction initiative. However, they are not that easy to find. The Chesapeake Bay Foundation last year initiated Toxics Use Reduction Planning Bills in three state legislatures that do not already have such laws. Repeatedly, we are told by the industry that they are already doing Use Reduction; however, we have been very hard-pressed to find examples. Without product- weighted materials accounting data over a series of years, we will never know how much potential we have to reduce, and thus, we will never be able to adequately weigh management options between pollution control and pollution prevention. Priorities need to be set, but they await use data.

The Maryland Chemical Industry Council, on the other hand, tells us that their goal is actually to increase the use of toxic chemicals. Albeit, not surprising, this suggests that our agendas are opposite. In their words "The goal of pollution prevention is to keep chemicals out of the environment - not out of manufacturing processes." They clearly are not concerned with the safety of workers, communities, or consumers. Although chemical manufacturers are quick to point out that they do not have the highest TRI emissions, when emissions are weighted against revenues, chemical industries come out squarely on top. We know this because of the availability of release data through TRI.

Currently some states have use reporting requirements and others do not. This may create an uneven playing field that submission of MA data would alleviate.

Additional Values in Issue Paper that are important to us.

1. It will give us something that we currently can not get. When this issue has been raised, industry has said they would not give us use data.

2. It will help track pollution prevention progress. Toxics Use Reduction is the most effective form of P2. We can not track this without use data.

3. Reporting may stimulate Use Reduction, in the same way that TRI reporting stimulated release reductions.

4. It will help prioritize the development of environmental technology and process changes to target chemicals that are highly used. Also MA data will help to identify alternatives.

5. Knowing use statistics would help us evaluate whether existing programs like 33/50 were really making a difference.

6. This would help industry evaluate and improve their own efficiency.

Source: RTK Net, Washington DC

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