Issues: Toxics

Comments on EPA's "Burden Reduction Options" Toxics Release Inventory (TRI) Program ID # TRI-2003-0001

Clean Water Action urges the Environmental Protection Agency (EPA) not to move forward with "burden reduction options" for the Toxics Release Inventory (TRI) program. The TRI program is critical for understanding pollution problems and for working for pollution prevention and cleaner communities. Individuals and organizations of all kinds rely on TRI data and use it to inform themselves and to develop ideas for reducing pollution that affects real people in real places.

Several of the options outlined contradict the intent of the program and threaten its ability to provide meaningful information to the public. For example:

  1. Exemptions for Small – Medium Size Business:
    Business size does not necessarily indicate amount of releases, and some releases that might be small in comparison to national figures are still significant in a particular community. The smallest businesses are already exempted.
  2. Raising Reporting Thresholds:
    The options for raising the reporting thresholds for a category of facilities or class of chemicals that represent a relatively small portion of overall TRI releases are similarly flawed. While a release may represent a small portion of overall national releases, it might involve a chemical extremely toxic in small amounts or highly persistent. Current regulations already exempt the majority of facilities in any given category; further exemptions could severely impact the ability of communities to get an accurate picture of pollution releases.
  3. Burden Not Reduced while Information Lost:
    Some of the options presented also appear to limit access to useful information while not resulting in any real reduction of effort for reporting facilities. Range reporting, for example, could obscure decreases or increases in releases but does not remove the facility's need to do calculations and to report. It does not appear that much is gained in terms of "burden" with this option, while much could be lost in terms of public access to information.

We urge the EPA not to move forward with reductions in TRI reporting and other "burden reduction" options at this time. EPA should be much more specific about facilities, chemicals and amounts involved in any proposed changes to TRI reporting so that the public may more adequately assess any such proposals in the future.

We appreciate the opportunity to comment on these options.

Submitted February 2004 by Lynn Thorp, National Campaigns Coordinator, Clean Water Action