Statement

ACC Applauds EPA TRI Burden Reduction Measure

Rule helps reduce burden while assuring appropriate information is available to the public

ARLINGTON, VA (December 20, 2006) – The American Chemistry Council (ACC) supports the Environmental Protection Agency’s (EPA) decision (December 18, 2006) to make final its proposed rule to expand the eligibility requirements for reporting certain releases to the Toxics Release Inventory (TRI) using Form A, the TRI “short form” report.  The changes adopted in the rule reflect EPA’s continuing effort to reduce the burden of TRI reporting on regulated businesses, while assuring that the quality of the TRI database is not compromised. 

As one of the most regulated industries in the world, America’s chemical makers have supported the TRI program since its inception.  EPA’s TRI program provides a useful database of release information that the American public expects and deserves.  ACC member companies believe there is significant value in TRI information as an indicator of environmental performance and keeping our communities safe.   ACC publicly posts member company’s TRI data as a performance indicator under its Responsible Care® program, available http://www.responsiblecare-us.com.  Since 1988 (the first year for which TRI data was reported), emissions for ACC member companies have decreased over 75%. 

According to EPA’s own estimates, the TRI program costs the regulated community some $650 million a year.  ACC has long supported EPA's efforts to realize efficiencies in the TRI program, and was an active participant in the two-year stakeholder dialogue that led to EPA’s current burden reduction proposal to expand the use of Form A.  Reducing the burden of program could mean important savings for both regulation community and EPA's program management, while assuring that the TRI database continued to provide useful information.

EPA’s burden reduction proposal will allow less than one-half of one percent of total release and waste management amounts to become eligible for Form A (short form) reporting.  Whether facilities adopt the short form, or continue to report on Form R (long form) depends on meeting the reporting criteria set out in the rule, corporate policy and commercial requirements.  ACC is pleased that EPA has taken this step to achieve further efficiencies in the TRI reporting program.

EPA also announced that it has decided not to pursue any changes in TRI reporting frequency at this time.  Although a change to TRI reporting frequency was not part of EPA’s original proposal, EPA’s Congressionally-mandated notice that it intended to discuss the parameters of possible changes in a future stakeholder dialogue was mischaracterized as a proposed change in reporting frequency.  ACC hopes that EPA will continue its inquiry into future TRI burden reduction measures that can achieve further efficiencies for the reporting community and enhancements to the TRI database.