April 1, 1999

Toxic Release Inventory

  • Susan Dudley

    Director, George Washington University Regulatory Studies Center
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Persistent Bioaccumulative Toxic (PBT) Chemicals; Proposed Rule; OPPTS-400132; RIN 2070-AD09

Stated Purpose:

"[T]o increase the utility of TRI to the public by adding a number of chemicals that are toxic and that persist and bioaccumulate in the environment to the section 313 list and by lowering the reporting thresholds for a number of toxic chemicals that have these properties."

Summary of RSP Comment:

The goal of TRI, to inform the public about hazards in their community, is intuitively desirable. However, since chemical releases are not equivalent to health or environmental hazards, TRI data on pounds of chemicals released fail to provide communities relevant information on risks that may be present. Furthermore, EPA data quality reviews reveal that, while reasonably accurate in the aggregate, releases reported on a facility basis may contain such large errors as to make the TRI data unreliable for site-specific analysis. EPA has also recognized significant limitations associated with even the aggregate numbers, which severely limit the TRI’s utility as a comprehensive database.

EPA has been requiring release information since 1987. Yet, the PBT proposal does not appear to have benefited from the experience of the last eleven years, nor from information available through various other agency efforts to reduce health and environmental risks from toxic chemicals. Despite extensive information on PBT chemicals, the reporting thresholds in this proposal are not based on any quantitative analysis of the magnitude of releases that will be captured, nor the risks posed by releases at different thresholds.

It is time EPA took stock of what TRI has achieved. While EPA and others may have been successful at providing easy access to TRI data, there is no evidence that it has been successful at informing consumers and citizens of real health or environmental threats. More information is not necessarily more valuable nor more relevant to communities. EPA should take seriously its responsibility for informing, but not alarming, communities, and should thoughtfully consider RSP’s proposals for increasing TRI benefits with a more targeted approach.