|Source:||EPA Office of Pollution
Prevention and Toxics Issues Paper
The EPA Office of Pollution Prevention and Toxics (OPPT) is currently reviewing issues related to the possible addition of chemical "use" data to existing information collection requirements. The overall project, considered under the broad concept of a "Chemical Use Inventory" (CUI), has been divided up into two tracks. The purpose of this paper is to provide background information on the track currently known as "TRI-Phase 3: Use Expansion" (TRI-P3), which addresses expansion of reporting requirements to the Toxic Release Inventory (TRI) to include chemical use data elements.
In order for EPA to effectively explore this issue, OPPT needs to understand what types of use information are considered most important to the various stakeholders, and to understand how the data would be used, whether for a single facility, or aggregated for national statistics. EPA also needs to understand issues related to the degree of burden created by any additional reporting requirements. This paper is intended to provide an overview of the issues, and to raise general questions to promote useful comments and discussion at the public meeting to be held on September 28, 1994.
BACKGROUND: THE ROLE OF INFORMATION STRATEGIES IN ADVANCING NATIONAL PROGRESS ON POLLUTION PREVENTION.
Over the last several years, environmental management strategies have shifted from an emphasis on controlling pollution to one of preventing it in the first place. In 1990, with the backing of states, environmental groups, and industry, Congress passed the Pollution Prevention Act (PPA). This law established an innovative national goal for environmental protection: to reduce or eliminate waste at its source, rather than trying to control it after it is produced. EPA is working to incorporate pollution prevention (P2) strategies into agency-wide programs, with OPPT serving as the "national program manager" for P2 efforts at EPA.
Among the many lessons learned from the shift to P2 is that new strategies are needed to motivate environmental protection. New strategies developed by OPPT include:
Empowering the broadest possible initiative from industry, the public and government agencies by providing information and support.
Establishing, in conjunction with others, national goals and measures of progress for addressing toxic chemical issues. (OPPT, 1993)
For EPA, the collection and dissemination of environmental information is integral to implementation of these strategies. The national experience with TRI has led to increased appreciation for how information can motivate initiatives that reduce pollution. TRI is a publicly available database that contains specific toxic chemical release, transfer, and waste management information from manufacturing facilities throughout the United States. TRI works by making information available to public rather than by setting emissions standards. In many cases, the information collected for TRI had not been previously collected by companies, and the resulting data served to inform and direct corporate efforts to reduce pollution. Easy access to TRI information promotes and empowers initiatives at all levels - from facility teams, to local environmental groups, to trade associations, to state and federal government agencies. By giving everyone the ability to participate in a broader national effort to address chemical issues, TRI information serves as a powerful driver towards reducing the entry of toxic chemicals into waste streams - and ultimately, into the environment.
OPPT is interested in the appropriate expansion of information tools such as TRI to further promote P2 activities nationwide. This is consistent with agency-wide efforts to view information as a strategic resource to be shared and used to set national goals. The TRI experience reinforced the lesson of the common saying that "what gets measured, gets done". One of the most important roles that government can play is in working with stakeholders to decide what needs to "be measured" so that national information systems can be established to fill important data gaps. In many respects, TRI-P3 is linked to general questions about the type of information that will be most useful in sustaining pollution prevention efforts over the long term.
The CUI initiative is based on increasing awareness that use is an important category of information for priority-setting. EPA environmental policies emphasize finding and targeting higher risks for priority actions. While TRI enjoys broad support, some critics say that EPA needs to find ways to give a better indication of possible risks. Exposure is the key to risk, and use is an important surrogate for exposure. Use information defines potential exposure.
In addition to its value for risk prioritization, facility level use information can also help to define opportunities for P2. Thus use data serve dual goals: better P2 efforts and enhancement of risk information available to the public. EPA wants better use data for its own priority-setting. EPA also wants to better understand the information needs of the public: what type of use data would be most valuable for public initiatives?
OPPT launched an initiative to discuss the idea of collecting use data with stakeholders from the toxics community in 1993. These discussions led to a multi-stakeholders meeting held in January of 1994. One outcome of the meeting was learning that different groups had different meanings for the concept of chemical use. Three important and interrelated categories were described:
- use as....function or application information (e.g., lubricant vs adhesive)
- use as....process condition information (e.g., closed vs open system), and
- use as....input and materials flow (e.g., the amount used in a given process)
OPPT learned that there was great interest on the part of the environmental and environmental justice stakeholders on the third concept - use as input information. In addition, these groups were interested in public access to this information via TRI.
This type of information is also known as "Materials Accounting" data. Materials accounting (MA) consists of determining the quantity of a chemical at key junctures in its progression through a production facility. These "throughput" measures track inputs and outputs and are described in more detail later in this paper. Labor unions also indicated interest in input data, plus they were interested in expanding TRI to make it a better screening tool for occupational exposure issues. These stakeholders describe materials accounting information as a legitimate right-to-know issue, and as critical information for gaining perspective on the P2 performance of facilities and industries. In general, industry stakeholders were uncertain of the value added by materials accounting information, and were concerned about the burdens involved in providing such data.
In response to stakeholder interest, OPPT management decided to create two CUI tracks:
- The IUR track involves revising the TSCA Inventory Update Rule (IUR) to gather chemical end use data related to function and condition of use. The next milestone for this track is an October 1994 meeting to initiate a negotiated rulemaking. (For further information, contact project manager Ward Penberthy at 202-260-1664.)
- The TRI-P3 track is intended to further explore materials accounting issues as described in this paper.
TRI AS A VEHICLE FOR USE INFORMATION
TRI was established under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). EPCRA was passed in response to public concern about chemical releases in communities following the 1984 Bhopal disaster. TRI requires data submittal on standardized questions for entry into a national database. Collected information originally covered releases to all environmental media, plus transfers of chemicals offsite for the purposes of treatment and/or disposal. About 23,000 facilities currently report.
The Pollution Prevention Act of 1990 expanded TRI reporting requirements. This legislation required the creation of a source reduction and recycling report within the existing TRI Form R to collect information on quantities entering waste streams including amounts treated and recycled, both on and off-site. Facilities also report qualitative information on source reduction efforts. The purpose of these new data elements was to provide information which would allow evaluation of progress in implementing national pollution prevention objectives.
In January of 1994, EPA proposed that 313 additional chemicals be added to the original 337 TRI substances. This "phase 1" expansion is expected to be finalized by November 30, 1994. EPA is currently evaluating the inclusion of non- manufacturing facilities as a "phase 2" of TRI expansion. EPA plans to issue a proposed rule on phase 2 by the Spring of 1995.
According to environmental, labor, and environmental justice groups, the features and importance of TRI make it the best vehicle for materials accounting information. Also, the materials accounting data complement the existing TRI data. Any addition of data elements related to use would be part of a phase 3 of TRI expansion. It would follow the chemical and industry expansion efforts.
TRI's LINK TO MASS BALANCE/MATERIALS ACCOUNTING.
The congressional negotiations that led to EPCRA included discussion of "mass balance" information. Mass balance is an engineering term for a procedure that identifies and compares all chemical inputs at a facility with the outputs and accumulations. Engineering measurements are taken and the resulting numbers are then examined to see if the inputs and outputs match. Proponents of mass balance type studies stated that these procedures would provide an important ledger-sheet check on TRI estimates, and that chemical inputs and outputs were themselves a right-to-know issue. Opponents of including this type of information questioned the need for information that went beyond release data, and they expressed concerns over trade secrets, the cost of generating such data, and the accuracy it provides.
The final version of EPCRA did not include reporting on mass balance or throughput data. However, Section 313(l) of the law did require that EPA arrange with the National Academy of Sciences (NAS) to study the utility of mass balance information. The resulting 1990 study, entitled: "Tracking Toxic Substances at Industrial Facilities" looked at the contribution that this type of information can make to assessing the accuracy of chemical release estimates, evaluating waste-reduction efficiency, and providing perspective on chemical management practices. In addition to describing the pros and cons of this approach, the NAS study made a distinction between engineering mass balance, which is a more complex exercise, and materials accounting, which uses readily derived accounting and production information, such as invoices for raw material purchases, inventory, sales, and product composition. In general, materials accounting (MA) is seen as the type of information that is most relevant for P2 tracking purposes.
TRI currently includes features which address use to some degree. For example, facilities must report the use category for the chemical: whether the chemical is being manufactured, processed, or otherwise used. There are 13 additional codes within these three major categories (e.g. manufacture for on-site use/processing vs manufacture for sale/distribution). In addition, mass balance is one of the recognized methods for estimating TRI releases and transfers. The new pollution prevention data elements also list mass balance as one of the methods for identifying source reduction opportunities.
Several states have passed legislation that requires materials accounting information. New Jersey has been collecting MA data under a state right-to-know act since 1987. Massachusetts began annual reporting of materials in 1990 as part of its Toxic Use Reduction Act. At least 15 states have some type of law that requires designated facilities to create comprehensive pollution prevention plans. Several of these states have partial reporting requirements in support of facility planning activities. Oregon's 1989 law requires that the amount of chemical brought on-site be reported. Maine requires companies to collect MA data, but the state does not collect the data each year. Instead, the state can review the data for facilities that are not meeting pollution prevention goals. Several other states such as Maryland have also had reporting requirements.
SUPPLEMENTAL TRI INFORMATION UNDER CONSIDERATION
MATERIALS ACCOUNTING DATA ELEMENTS.
There are six basic calendar year throughput measures which could be added to existing TRI data elements to allow materials accounting:
- Starting inventory (as of January 1)
- Quantity brought on site (during the calendar year)
- Quantity manufactured on-site
- Quantity consumed in process
- Quantity in (or as) product (shipped off-site)
- Ending inventory (as of December 31)
In addition to these basic measures, two other issues are emerging as important for materials accounting:
- Substitute information, so that replacement chemicals can be listed and tracked. This information can be used to identify successful substitution strategies, and as a check on possible practices where non-TRI but nevertheless toxic chemicals are used without any reductions in throughput. For example, in the case where substitution eliminates the need to file a Form R, the identity of the substitute might be provided.
- Process-level reporting, because this is where source reduction occurs, and because it affords the most accurate way to measure P2 progress. This is a key piece of the use picture, and EPA is looking for input from stakeholders on this issue. Studies by the Congressional Office of Technology Assessment (OTA) and the NAS concluded that waste reduction data should be process- specific or production-unit specific, because aggregation of data, even at the facility level, could mask P2 progress (OTA, 1986, NAS, 1990). Massachusetts requires that facilities define "production units" and New Jersey has also begun to collect "production process" information as identified by facilities. In both states, MA data collection is closely linked to source and use reduction planning and goal-setting, and process data is seen as key to these activities. The value of process data is clear, but it also increases concerns about trade secrets. In response, both states have developed hybrid systems where process data is generated for the use of the facility for planning purposes, and a subset of the data is available to the public.
The public data employs range codes for input quantities, and year-to-year changes are reported as percentages to further protect proprietary information. For example, New Jersey requires that the following information be reported as percentages for chemicals in targeted processes: changes in toxics use per unit of production, and changes in non-product output (equal to releases, transfers, and wastes) per unit of production. Process reporting is an important TRI-P3 issue: it appears to have the biggest potential for stimulating source reduction, but it also complicates reporting. OPPT is interested in learning more about hybrid approaches to this issue.
OCCUPATIONAL DEMOGRAPHICS DATA.
Given TRI's role as the major public database for tracking toxics and pollution prevention issues, worker safety advocates are interested in seeing TRI expansion efforts include data elements relevant for occupational health screening purposes. EPA is interested in exploring this issue further. Possible data elements include the following:
- Total number of workers at the facility.
- Number of workers potentially exposed to the chemical.
- Whether exposure monitoring has been performed for this chemical during the year - yes or no.
- Whether exposure monitoring has ever been performed for this chemical - yes or no.
This type of information would also be useful for screening and follow-up activities. In some cases, facilities have information on the number of exposed production and maintenance workers via results of exposure monitoring programs. In other cases, exposure monitoring data are not available, but employers have estimated who is potentially exposed for hazard communication training or other purposes.
Other elements? OPPT is interested in receiving information about other useful occupational data elements. For example, NIOSH suggested that the number of workers could also be broken down by gender or race to provide additional demographics. Another suggestion was that if exposure monitoring has been performed, to ask if any of the measurements have been at or above one-half of the OSHA Permissible Exposure Limit (PEL). It is important to point out that OPPT does not view TRI as the appropriate vehicle for reporting of actual occupational exposure data. This is why the information is described as occupational demographics data rather than occupational exposure data. It may be that a separate effort is needed to discuss the possibility for a national occupational exposure database to collect such information. EPA is interested in additional discussions with occupational agencies and stakeholders on this issue if this is the case.
The EPA Science Advisory Board has identified workers' exposures to chemicals in industry as one of the highest risk areas for significant impacts to human health. OSHA and NIOSH have stated that TRI's utility for screening occupational issues would be greatly improved with information on the number of workers involved. These types of data elements, combined with materials accounting data, would help to integrate pollution prevention and occupational exposure prevention efforts.
HOW MIGHT MATERIALS ACCOUNTING DATA BE USED? HOW IS IT CURRENTLY USED?
The basic rationale offered by advocates of materials accounting begins with the fact that the environmental data kept by industry reflects the end-of-pipe regulatory requirements that preceded the shift to P2. While important, this information reflects control and management of pollution, and does not provide a complete information basis for P2. If environmental practices are to shift towards a P2 emphasis, there is a need to track P2 progress. Pollution prevention is about making changes to the process, and thus process information is a logical prerequisite for finding P2 opportunities. TRI-P3 is linked to discussion about what are the best "metrics" for a true P2 scorecard, and about what information is best for promoting facility P2 planning.
TRI currently provides important information on release and transfer totals, which appears to be the information of primary concern to most communities. TRI includes data on waste generation and waste management, and it also allows tracking of some P2 issues, but it does not give the full picture. For example, Hearn and Aucott (1991) state that information on releases and transfers, while important, does not by itself allow tracking of P2 progress. Release reduction is not the same as source reduction, as levels may reflect end-of-pipe controls, or changes in production levels. In addition, source reduction efforts might not always lead to a reduction in environmental releases, but might serve to reduce occupational or consumer exposure levels to toxics. Hearn and Aucott (1991) provide the example of reformulating a shampoo to remove formaldehyde as an ingredient. This measure would reduce the quantity of formaldehyde stored and used in the workplace, and would decrease any consumer exposures irregardless of any impacts on releases.
Materials accounting proponents also point to chemical accidents and "green" product issues as additional areas of public interest not addressed by current TRI information. They state that MA data provides the storage, transportation, and process flow information that is useful for dialog on chemical accident release prevention. Existing TRI data involve waste streams, which are not the focal point for chemical accident prevention. Increased ability to follow and track toxics in products is also seen as an emerging area. For example, a study of 1991 Massachusetts MA data found that the amounts of toxic chemicals shipped in products was three to four times larger than the statewide totals for releases and transfers (Burns and Gray, 1993).
DESCRIBING THE FULL PICTURE.
Advocates of MA claim that it can fill some of the information "gaps" needed for a better picture of P2 activities. They have described these gaps in a variety of ways:
INFORM (1993) uses the term "product stream" to describe the input and product output data needed to allow materials accounting. According to INFORM, TRI currently collects important "waste stream" data, but the product stream data are needed to complete the picture.
The Working Group on Community Right-to-Know describes three possible paths for a chemical at a facility: it can be consumed during production, it can become part of the facility's waste stream, or it can become part of a product. (WGCRTK, 1991) According to the Working Group, toxics release data by definition only tracks toxics at one part of one path: the waste stream. In order to better track P2 efforts, and to fully inform the public, information along all paths should be tracked.
A case study analysis of New Jersey throughput data by the State Department of Environmental Protection and Energy put MA data into perspective by describing all P2 efforts as falling into one of three major categories of manufacturing changes as follows:
- reduced inputs - reducing the quantity of toxics used per unit of product produced.
- better production efficiency - reducing the quantity of toxics generated as nonproduct output prior to recycling, treatment, or disposal, and
- better product design - reducing the content of toxics in manufactured goods per unit of product.
According to the NJDEPE analysis, TRI only provides partial insights into production efficiency. Materials accounting data supplement TRI by providing the missing production information to complete the picture for production efficiency, and they fill information gaps on the other two activities. (NJDEPE, 1993).
POSSIBLE USES OF MA DATA.
Based on discussions with MA advocates, a few examples of how the data might be used are described briefly below:
PROVIDE A SCREENING LEVEL CHECK ON TRI DATA. MA data is helpful in detecting gross errors in reported environmental releases, transfers, and waste management totals. As with financial accounting, a ledger-check balance can be performed to check whether inputs match with outputs.
PROVIDE INFORMATION FOR EMERGENCY PREPAREDNESS REVIEW. Chemical accidents are an important concern for many communities. TRI currently requires that facilities report ranges of the maximum amount of material kept on-site. This information is useful, but MA data provides a more complete picture, so that right-to-know information on the kinds and quantities of chemicals being transported through a neighborhood can be tracked. Such information might be useful to local community groups, emergency response groups such as "Hazmat" teams, and other local and state groups. An example of this potential can be seen by looking at INFORM's study of New Jersey data to compare two facilities that report to TRI for the highly toxic substance phosgene.
1991 TRI data for phosgene at two New Jersey facilities: Hatco Corporation Dupont Corporation Fords, NJDupont Deepwater, NJ Total releases and transfers 10 pounds 1,298 pounds Wastes destroyed by treatment 973,600 pounds 598,000 pounds Maximum amount on-site at any time during the year 10,000-99,000 100-999 pounds pounds(range) (range) Use category Process Manufacture and Process
The TRI data elements provide important data, but do not give a clear picture of what is going on. For example, the releases and transfers for Dupont look high in comparison with the maximum amount on-site. Materials accounting fills in important data as follows:
1991 Materials accounting data from New Jersey Hatco Corporation Dupont Corporation Starting inventory 26,000 pounds 0 pounds Quantity brought on-site 4,868,000 pounds 0 pounds Quantity produced on-site 0 pounds 58,400,000 pounds Quantity consumed in process 3,878,399 pounds 57,800,000 pounds Quantity shipped in (or as) product 0 pounds 0 pounds Ending inventory 42,000 pounds 0 pounds
The MA data give more of the picture. Dupont manufactures a large amount of phosgene overall, but the data indicate that they are making the phosgene as needed so as to minimize the storage and potential for accidental release of large volumes of phosgene. Hatco does not make phosgene, and must transport the toxic material to the plant and store it for use.
This data would give local groups working on emergency response a "heads-up" on areas to pursue further to maximize local emergency preparedness. For Hatco, transportation, storage, and loading/unloading issues might be targeted for review.
This example also shows how MA data might be viewed as a right-to-know issue for local groups. For the Dupont facility, potential transportation concerns can be ruled out, and the process used to manufacture the phosgene seems inherently safer with its low volume of stored phosgene on-site at any one time. But the overall quantity produced on-site, and the TRI releases might focus review on process-safety issues.
PROVIDE NEW "METRICS" FOR MEASURING P2 STATUS AND PROGRESS. MA data, when combined with TRI data, allow for the development of new P2 measures that look at efficiency in materials usage by indexing wastes and releases to throughput. This type of information might provide a good driver of P2 actions in smaller and medium size firms that do not make the local or national "top-ten" list for releases and transfers.
Indexing might also provide important perspective in evaluating large releasers. Large plants tend to be judged on the overall size of their releases, rather than how well they handle larger amounts of chemical throughput. Materials accounting data supports benchmarking on waste generation rates, thus providing another side of the picture. Large releasers will always be important, especially for nearby communities, but rates are also useful for tracking facility P2 progress over time. By bringing throughput information into the picture, the performance of larger facilities can be examined in a broader context.
The extent to which such measures can be used to compare different facilities needs further review. Differences in release-to-throughput ratios among facilities might be due to very different processes rather than to differences in source reduction progress. For example, an EPA-sponsored study using New Jersey materials accounting data looked at a case comparing releases among 6 facilities. Releases from five smaller plants were equivalent to the releases from one large releaser (51,863 vs 55,784 pounds respectively). However, MA data showed that the throughput data from five smaller sites were much less than the throughput of the larger facility (28,613,005 vs 100,041,766 pounds respectively)(Saxton et al. 1994). This might be related to differences in "efficiency", or it could be due to nature of the processes involved. EPA is interested in further exploring the opportunities and limitations involved in comparing normalized data among facilities.
GAIN INSIGHTS FOR FURTHER REVIEW OF PRODUCT-RELATED TOXICS ISSUES. MA data provide screening-level information on the presence of toxics in products. It could provide a roadmap for follow-up, and if pursued could allow improved capabilities for life-cycle analyses, product stewardship efforts, and similar initiatives from chemical manufacturers, state and federal agencies, and other stakeholders. For example, a study done using Massachusetts MA data included a look at the 15 facilties reporting TRI releases of perchloroethylene (Burns and Gray, 1994). Three of the facilities used perchloroethylene in their products, and because the Massachusetts law requires facilities to develop a production unit code to categorize the use, it was possible to learn that one facility uses the perc as an ingredient in aerosol can products. While the facility reported only 649 pounds of releases and transfers during the use of 75,822 pounds of perc, the 75,173 pounds that are put into product can be assumed to be eventually released to air in other settings. The nature of aerosol products is that they are released to air in close proximity to the user. Given the toxicity of perchloroethylene and the potential for exposure, this particular use might be followed up as a product stewardship issue by perc manufacturers, or be screened for further action by government or environmental groups. The capability to estimate the amounts of toxics in products could provide important leads for pursuing issues related to indoor air quality, consumer exposures, and household hazardous wastes.
PROVIDE A FRAMEWORK THAT ALLOWS INCREASED FLEXIBILITY FOR COMPANIES. Part of the shift to P2 strategies is a move away from command and control specification regulations. MA data set the stage for giving companies increased flexibility in how they reduce pollution levels. MA data gives government regulators and environmental stakeholders the information they need to be confident that pollution is not being shifted instead of reduced. Being able to track environmental "performance" is viewed by some as a prerequisite for such approaches. The 1993 National Performance Review report prepared by the Office of the Vice President states that: "In the long run, credible measures of performance are critical to providing industry with the kind of flexibility needed to optimize investments in pollution prevention". The report goes on to recommend that EPA create a database that includes "...an inventory for measuring, on an industrywide basis, changes in the use of toxic chemicals and pesticides." (NPR, 1993)
INFORM NATIONAL EPA INITIATIVES ON P2. National MA statistics might be useful for a variety of initiatives. For example, the data could be used for industry sector approaches such as the "Common Sense Initiative", or projects to incorporate source reduction at the process level such as the "Source Reduction Review Project". They could be incorporated into ongoing efforts to integrate environmental and financial accounting systems, and into agency efforts at defining sustainable development and clean production. They could also be used in designing a new generation of voluntary programs, and for promoting facility planning for P2. It is likely that MA data would be very useful for national efforts at multi-media permitting, and for streamlining of media-specific reporting requirements. Materials accounting data could also be used to generate hypotheses or guide research issues. For example, a study of the long term release of heavy metals into the environment needs to look beyond industrial waste streams. A 1993 Office of Technology Assessment report entitled "Green Products by Design" included analysis of 1990 New Jersey MA data showing that 83% of cadmium, 92% of nickel, and 99% of mercury used by manufacturing facilities was converted into products. These products need to be followed to learn about eventual releases to the environment.
REPORTS OF CURRENT USE OF MA INFORMATION. States. The main focus to date of both Massachusetts and New Jersey has been to put their own programs in place, and to assist industry with starting up their recordkeeping. It is important to understand that both states view the data primarily as a tool to be used by facilities in developing source and use reduction plans that will allow the accomplishment of statewide goals. The plans include facility goals for reductions over time, and both states use reporting information as "progress reports" so as to target technical assistance on use and source reduction.
Representatives from both states provided anecdotal evidence that MA data collection and tracking greatly improves understanding of waste generation at the process level, and that the resulting insights are very useful to facility managers in identifying opportunities for reduction. This increased awareness was described as being equivalent to that brought about by TRI itself. Additional information is provided as follows:
Massachusetts - State DEP compliance inspectors now organize their reports by production unit, as this makes it easier to articulate source reduction opportunities identified during the visit. In addition, this infomation is used to make referrals to the state Office of Technical Assistance (OTA), and the Toxics Use Reduction Institute (TURI). In turn, these groups perform analysis of state data to identify processes and chemicals where applied source reduction research is needed. For example, TURI is evaluating alternative surface cleaning methods in response to the widespread use of solvents for cleaning (Rossi and Thomas, 1994). The MA data is also being used in a statewide effort to map facilities for use in identify possible contributors to Superfund sites, and for targeting inspections in areas where groundwater needs to be protected. Over the next few years, the state DEP is planning a variety of projects, such as using "efficiency" data from facilities to target technical assistance, and for improving multi-media permitting initiatives. Based on their experience with the data, a national database was strongly recommended.
New Jersey - The NJDEPE has focused its efforts on developing guidance and performing outreach on the new requirements of the state's 1991 Pollution Prevention Act. The strategy is to work with industry on planning so that state reduction goals are achieved. The new process data is expected to be very useful for identifying source and use reduction opportunities. The NJDEPE has future plans to incorporate this data into multi-media permitting efforts, and to explore other issues as well.
The NJDEPE published "Materials Accounting as a Potential Supplement to the Toxics Release Inventory for Pollution Prevention Measurement purposes: A Case Study Analysis of New Jersey Throughput and TRI Data" in December of 1993. This study included 30 case studies where TRI and MA data were examined to identify whether pollution prevention was occurring. The study found that MA data, when combined with TRI data, allowed for a more comprehensive analysis of P2 progress.
General state outlook - A 1994 survey of state TRI contacts performed by the National Conference of State Legislatures found that TRI was most commonly used by states for pollution prevention initiatives. In addition, the survey found that the use of TRI to track facility P2 efforts was the activity increasing most rapidly. (NCSL, 1994) Given the interest of states in tracking P2 efforts, and the utility of MA data for this activity, it is likely that states would be interested in using MA data for P2 scorecard purposes.
INDUSTRY. While materials accounting has not been included in any corporate reporting guidelines such as the CMA pollution prevention code or the Public Environmental Reporting Initiative (PERI), there are some indications that industry does use MA data. For example, it is reflected in a 1991 study performed for the Presidents Commission on Environmental Quality on the use of total quality management (TQM) tools for pollution prevention. While all 11 facilities studied used TRI data as part of their metric baselines, 6 of the firms also created additional indexed metrics by combining TRI data with materials accounting type information collected for the project. For example, a 3M facility in Brookings, South Dakota used a waste ratio prepared by dividing waste by output. Output was defined as pounds of waste, byproduct, and product. The report concluded that facilities should use additional metrics for tracking P2 progress. Indexed metrics were described as especially useful for motivating facility teams for pursuing project goals, and for communication with environmental groups and regulatory agencies. (PCEQ, 1993)
The Polaroid company provides another example. As part of a Toxic Use and Waste Reduction Program begun in 1988, the company developed an "Environmental Accounting and Reporting System" (EARS) to collect comprehensive materials accounting and waste generation and disposition data. The EARS spreadsheet enables Polaroid engineers to track and improve existing processes and to review the impact of new chemicals before the company makes a committment to their use. Teams can track the flow of candidate chemicals to estimate and compare the amounts of pollution that would be created in the manufacturing process. The resulting information can be used to determine "efficacy" - is this chemical the best choice for the intended use? According to Nash et al. (1994), the data requirements for this system have forced employees to increase their understanding of their processes, and this has led to uncovering opportunities for source reduction.
Industry has previously opposed materials accounting as an appropriate area for TRI. In general, industry does not necessarily view use as equating with risk, and is concerned that use volumes might lead to public confusion about risk. Other concerns address the potential for loss of proprietary information, especially to foreign competitors, and the reporting burdens posed by such reporting. EPA is interested in hearing about industry experience with the state MA laws, current positions on materials accounting, and lessons learned about the best ways to motivate and measure P2 progress at the facility, company, and national level.
PUBLIC INTEREST GROUPS. A variety of reports, several of which are referenced in this paper, have been prepared by public interest and environmental groups using state MA data. In general, these groups have used MA data to show how they complement TRI to give a more complete understanding of toxics at facilities and in commerce. Other studies are also in the planning stage. Environmental groups believe that MA data allow a much better perspective on whether reductions in releases and wastes are actually due to source reduction. They are also interested in issues such as the following: how MA data can serve to motivate facilities to aggressively pursue source reduction, how to best judge P2 progress from the facility level on up, how to track the presence of toxics in products, and how to minimize the shifting of toxics. These groups strongly support the idea of creating use reporting on a national level.
HOW MIGHT OCCUPATIONAL DEMOGRAPHICS DATA BE USED?
Information on the numbers of workers potentially exposed to a given chemical can be extremely useful for a range of activities. Similar data previously gathered by NIOSH as part of the "National Occupational Exposure Survey" (NOES) continue to be used by government agencies for priority-setting despite the fact that they are over 10 years old. NIOSH does not have the funding to update the NOES survey, and NIOSH strongly supports the idea of using TRI to provide similar types of estimates on a regular basis.
While the NOES survey had a broader scope, covering more information and more types of workplaces, the TRI information is more "user friendly". The TRI experience has shown that this capability encourages the use of the data by many different groups. Some possible examples are described below: Labor organizations could use the data to help them identify and prioritize local unions for outreach and training on a given chemical. The information might also assist efforts to integrate occupational and environmental efforts. CHEMICAL MANUFACTURERS could use customer data for estimating use and exposure patterns for product stewardship evaluations of their products. They could also use the information to identify customers that might need assistance.
TRADE ASSOCIATIONS could use the data to rank chemicals and potential exposures for industry-wide efforts to identify and disseminate information on best practices for reducing exposures.
STATE OSHA CONSULTATION PROGRAMS could use the information to identify and prioritize facilities for targeted assistance on chemical-specific issues.
NIOSH COULD USE THE DATA for prioritizing chemicals for review, for screening candidate facilities for inclusion in industry-wide studies, or as a tool for targeting facilities for outreach for important chemical hazard bulletins.
OSHA COULD USE THIS DATA as part of prioritization for rulemaking, and for targeting of scarce inspection resources. It could provide a basis for new types of interventions, from industry-specific initiatives to voluntary programs.
EPA COULD USE THIS INFORMATION to prioritize chemicals for testing, and for risk screening purposes. EPA could also use the information to further develop the link between source reduction and reduction of worker exposures.
In addition to the information on the numbers of exposed workers, the materials accounting information itself may prove valuable for occupational health initiatives. While environmental releases, especially those in the vicinity of workers, might signal the potential for exposure, some worker and environmental advocates have stated that worker exposures can also occur even where releases to air are not reported. This is because workers are in such close proximity to materials when working with them, that even small volumes, not always counted as releases, might still cause important airborne exposures. In addition, some chemicals such as glycol ethers do not volatilize easily, but can be associated with important skin absorption exposures. In sum, job-related handling of chemicals can lead to exposures even in cases where releases to the environment are not easily observed or quantified using TRI estimation methods. Neither release or throughput data can predict exposure, but both help in identifying facilities where exposure is possible. For this reason, worker advocates believe that materials accounting information, especially with added elements on the numbers of workers involved, would make TRI a better screening tool for tracking worker toxics issues.
WHAT WOULD BE THE VALUE OF A NATIONAL PROGRAM TO COLLECT MATERIALS ACCOUNTING DATA?
In exploring TRI-P3 further, EPA is interested in receiving comments on whether this subject area is appropriate for a national level program, or whether it is best left for state initiatives. Questions are provided below:
Do stakeholders believe that materials accounting data have real value in moving TRI closer to a "pollution prevention scorecard"?
Could these data be meaningfully aggregated across facilities, or is their utility limited to tracking single facility performance over time?
What types of national initiatives would MA data support? This could include national initiatives by the federal government, but also by trade associations, labor unions, or environmental groups.
What type of technical support would be needed for such a database?
Has state materials accounting data been accessible to local groups? If yes, EPA is interested in learning more about state delivery mechanisms. If no, what have the obstacles been?
What is the best way to address the issue of production process level data?
How critical is materials accounting data for tracking pollution prevention progress? Is industry using throughput information for P2 tracking and decisionmaking? Why or why not?
WHAT TYPE OF INFORMATION DOES EPA NEED TO PURSUE THIS ISSUE FURTHER?
EPA is interested in examples of how materials accounting data have been put to use, whether by companies, states, or community, environmental, or labor groups. EPA is also interested in future plans for using this type of information. This can provide important insights for possible development of TRI-P3.
EPA is interested in reviewing all reports that relate to materials accounting, especially those that include an aggregation of data.
There have been claims that much MA data might be considered "Confidential Business Information" (CBI). However, both Massachusetts and New Jersey report a CBI claims rate of less than 1% for MA data. EPA is interested in examples of cases where trade secrets were compromised or where CBI claims were needed.
To what degree do facilities already compile these data in the course of preparing annual TRI estimates? What are estimates for the resources needed to report MA data to EPA?
EPA PLANS FOR NEXT STEPS
Following the meeting, EPA will review the stakeholder comments in detail, and will prepare a list of candidate data elements for further review. For example, issues such as statutory authority for candidate elements will be reviewed. EPA will then prepare agency options for further consideration. EPA plans to continue dialog with stakeholders on this project. Please note that the name of this initiative may change as additional decisions are made on how to best pursue this issue.
Burns, P. and H. Gray 1994. Tracking the Toxics Crisis: A call for State Action on Toxics Use Reduction. Massachusetts Public Interest Research Group and the National Environmental Law Center.
Hearne, S.A., and M. Aucott, 1991. Source Reduction versus Release Reduction: Why the TRI cannot measure pollution prevention. Pollution Prevention Review, Winter 1991/1992.
INFORM. 1994. A Clearer view of Toxics: New Jersey's Reporting Requirements as a Model for the United States. INFORM NY, NY.
NAS. 1990. Tracking Toxic Substances at Industrial Facilities - Engineering Mass Balance versus Materials Accounting. National Academy Press. Washington, DC 1990.
Nash, J., K. Nutt, J. Maxwell, and J. Ehrenfeld. 1994. Polaroid's Environmental Accounting and Reporting System: Benefits and Limitations of a TQEM measuring tool. In Environmental TQM, Edited by John T. Willig. McGraw-Hill Inc. 1994.
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OTA. 1986. Serious Reduction of Hazardous Waste: For Pollution Prevention and Industrial Efficiency. Congress of the United States Office of Technology Assessment
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PCEQ, 1993. Total Quality Management: A Framework for Pollution Prevention. Quality Environmental Management Subcommittee, President's Commission on Environmental Quality. January, 1993.
Rossi, M. and K. Thomas. 1994. DRAFT REPORT -Phase 1 of the TURI Cleaning Alternatives Project: "Evaluation of Alternative Surface Cleaning Methods".
Saxton, J.C., S.J. Ratick, H.M. Garriga, A. Desai. 1994. Pollution Prevention Frontiers (PPF) and other approaches to Pollution Prevention Assessment. Comparison based on New Jersey Materials Accounting Data. Prepared for Pollution Prevention and Toxics Branch, EPA Office of Policy, Planning and Evaluation. Project Manager: Linda Feinstein Kareff. June 1994.
Working Group on Community Community Right-to-Know. 1991. Tracking Toxics for Pollution Prevention. Working Notes Newsletter. November-December 1991.
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