Responsible Care Communication

Chemical Manufacturers Association
March 10, 1995

To:	Responsible Care Communications Contacts
Subject:	Pollution Prevention Communications Kit

The Environmental Protection Agency is expected to make public the 1993 Toxics Release Inventory this month. If you have not already done so, CMA strongly encourages all member companies to proactively communicate emissions reduction and pollution prevention trends at their facilities.

The communications should be built around TRI performance for 1993 or, if you choose, for 1994. You should explain significant changes and give examples of timely pollution prevention innovations. Concrete future plans to further reduce emissions may be revealed. If possible, refer to Responsible Care.

We have prepared five Pollution Prevention Fact Sheets as the basis of our outreach to media and opinion leaders about the TRI. These are enclosed for your information and use, along with:

• Talking points, giving CMA's position on the Toxics Release Inventory and pollution prevention.
  
• Q&A's to help answer anticipated questions.
  
• Background papers on the Toxics Release Inventory and on pollution prevention.

Grassroots communication of industry's efforts to prevent pollution, illustrated with specific examples, is critical to reassure our communities and opinion leaders of the chemical industry's progress in reducing emissions and protecting public health. Should you have any questions about the kit or CMA's pollution prevention communications program, call Owen Kean at (202) 887-1201.

Sincerely,
Jon C. Holtzman
Vice President-Communications

cc: Responsible Care Coordinators (w/o enclosures)
Communications Contacts
Chemical Industry Councils
Environmental Contacts

2501 M Street, NW,
Washington, DC 20037
Telephone 202-887-1100
Fax 202-887-1237

Talking Points Pollution Prevention

March, 1995

Primary Messages

• From 1987 to 1993, the US chemical industry reduced by half releases of toxic chemicals to the environment, according to reports prepared for the Toxics Release Inventory, a key measure of industry's efforts to prevent pollution. In addition, the industry reduced offsite transfers for treatment and disposal by 55% and material disposed of in EPA permitted deepwells by 45%. At the same time, chemical production increased by 18%.
  
• The reductions in 1993, EPA's current reporting year, were the largest ever. A CMA survey showed one-year cuts of 16% in releases, 14% in underground injection and 21% in transfers, excluding transfers for recycling and energy recovery. If these are included, the reduction in transfers is 31%.
  
• The survey of byproducts generated, required by the Pollution Prevention Act, reveals that 94% were recycled, recovered for energy or treated in 1993. These byproducts are a much larger universe than the original TRI, one that is more difficult to measure and that includes future projections. CMA members companies anticipate an increase in recycling, recovery and treatment, taken together; and a further reduction in releases to the environment.

Other Messages

• A driving force for pollution prevention is CMA's Responsible Care. The initiative was introduced in 1988 to improve the chemical industry's safety and environmental performance and to respond to public concerns about chemicals. It is an obligation of membership in CMA, whose member companies represent 90% of the productive capacity for basic chemicals in the US.
  
• The chemical industry supports the public's right to know about industry wastes and emissions, CMA backed the Community Right-to- Know Act in 1986 that created the Toxics Release Inventory, and was an early supporter of the Pollution Prevention Act of 1990 which expands the information on waste management available to the public.
  
• The chemical industry questions changes that EPA has proposed which would substantially alter the composition and purpose of the TRI. The addition of chemical use reporting is unrelated to risk reduction and would place US companies at a competitive disadvantage. The wholesale expansion of chemicals on the list and the sectors that must report would reduce the effectiveness of the TRI as a guide to pollution prevention.

Questions and Answers

Q: What is the basis for the estimate of the chemical industry's TRI in 1993?

A: CMA surveyed 55 of its member companies, responsible for 90% of our members' and transfers, to determine the percentage change from 1992 to 1993. This was then applied to 100% of the releases and transfers for 1992 to arrive at an estimate for 1993. Later this year CMA will publish its annual progress report, "Preventing Pollution," using data submitted to EPA by all member companies.

Q: Why are you reporting 1993 performance now?

A: CMA's outreach is timed to coincide with EPA's publication of the Toxics Release Inventory, which comes two calendar years after the actual releases and transfers. Individual companies may release their TRI reports a year earlier, when they are submitted to EPA.

Q: Why are you using 1987 as the base year?

A: This was the first year the TRI was compiled. While EPA opted to use 1988 as the base year, citing concern about data quality, CMA elected to stay with 1987 for this outreach. Reduction of releases by CMA member company plants from 1988 to 1993 were 44%, vs. 49% from 1987.

Q: To what extent is the public being exposed to these chemical releases?

A: Release doesn't equal exposure, according to EPA. Estimating exposure requires analysis of the characteristics of the chemical, the location and the individual. Natural environmental processes can transform a chemical (e.g., sunlight decomposes some chemicals), transfer it from one medium to another, dilute it or concentrate it.

Q: Some of your company's wastes are transferred off-site. Where do they end up?

A: In most cases, they are shipped to another company location for treatment or disposal. We manage most of the wastes ourselves in state-of-the-art facilities. In some cases, wastes are handled by publicly owned or commercial facilities licensed for waste treatment and disposal.

Q: What are "wastes" generated?

A: Originally the TRI reported chemicals released to the environment. In 1991 EPA added to the TRI materials produced in manufacturing that are not released. Instead, they are recycled, recovered for energy or treated. EPA labels them "wastes." CMA feels a more accurate description is byproducts, since most are not discarded but utilized for manufacture or in products.

Q: Don't we use too many toxic chemicals in the manufacturing economy?

A: TRI chemicals, while toxic to varying degrees, make a valuable contribution to our economy and the nation's standard of living. They are important and often irreplaceable in solving problems, curing diseases and improving safety and security. And emissions are being reduced, while chemical production is increasing.

Background Pollution Prevention

The past decade has seen the emergence of a pollution prevention ethic in US industry and government. The chemical industry has practiced prevention for almost a century in the form of yield improvement -- the art of making more product with the same amount of raw material.

Pollution prevention is one of the six codes of the Chemical Manufacturers Association's Responsible Care initiative. This requires that companies, as a condition of CMA membership, establish and execute pollution prevention programs and share the results with the public.

Preventing pollution involves a hierarchy of waste management techniques that begin with source reduction and includes recycling and reuse, energy recovery, and treatment. CMA strongly believes that using a hierarchy is the most effective way to restrict releases of hazardous substances to the environment, reduce wastes generated by facilities and properly manage the remaining wastes and releases.

The key lies in giving facilities the flexibility needed to develop site-specific pollution prevention strategies. No single strategy can be a universal, turnkey solution in an industry that encompasses tens of thousands of facilities and hundreds of thousands of processes. Successful projects aimed at reducing and preventing pollution are enormously complex and often take years to implement. Nonetheless, CMA members -- voluntarily and vigorously-- are pursuing pollution prevention, beginning with source reduction.

Source reduction incorporates ways to eliminate waste before it is generated, such as:

• modifying equipment, technologies or procedures, including recycling, that are integral to the production process;
  
• instituting management and training programs that improve housekeeping, inventory control, materials handling or other operational procedures;
  
• making raw material substitutions and reformulating or redesigning products.

The chemical industry is making steady progress in reducing releases. Based on TRI reporting, CMA companies which account for more than 90% of US productive capacity for basic industrial chemicals, have reduced releases of listed chemicals by 49% from 1987-1992. Industry production rose by 18% during that time.

Background Toxics Release Inventory (TRI)

Since 1987 EPA has published the Toxics Release Inventory, information about the release of toxic chemicals from US manufacturing facilities. The TRI is contained in a computerized database, available to the public, that can be analyzed by individual chemical, by particular facilities and in many other ways.

"It was envisioned from the outset" says former EPA Administrator William K. Reilly, "to make data publicly available so that knowledge could be a catalyst for pollution prevention activities."

TRI reporting requirements cover 20 categories of chemical compounds and more than 320 individual toxic chemicals. The current TRI list covers a spectrum from mildly toxic to acutely toxic. The chemicals run from the familiar, such as ammonia or saccharin, to the exotic, such as osmium tetroxide, a fixative for electron microscopy. They vary widely in the frequency, amounts and industrial processes in which they are used.

In 1992 nearly 24,000 facilities reported to EPA. Releases totaled 3.2 billion pounds, down from the previous year. Off-site transfers were more -- 4.7 billion pounds -- but two-thirds consisted of transfers for recycling. Total byproducts generated increased slightly to 37.3 billion pounds.

A chemical is defined as toxic if it causes adverse effects in humans or the environment. The dose makes the poison, according to toxicologists. That is, for some chemicals, toxic effects can be seen after human exposure to a small dose. For other chemicals, toxic effects occur only after massive doses. The point is that exposure is just as important as toxicity when determining therisks posed by chemicals in the environment.

TRI data does not indicate the level of human or environmental exposure. Landfills and underground injection are designed to isolate wastes and thus result in a very low potential for human exposure. Even data on air and water releases cannot be directly equated to exposure since, as EPA says, "each chemical in each individual release circumstance undergoes different transformations after release."

For the TRI, Congress established these criteria for chemicals to be listed -- that the chemical be known or can reasonably be anticipated to cause a significant adverse effect, and that this determination be supported by "sufficient evidence" and "based on generally accepted scientific principles." As a starting point, Congress combined lists previously developed for a similar reporting law in New Jersey and for a voluntary industrial survey in Maryland.

EPA has added and deleted a few specific chemicals each year. Beginning in 1991, the Pollution Prevention Act greatly expanded the reporting requirements to include examples of source reduction and an accounting of TRI chemicals generated as byproducts and recycled, recovered for energy or treated. Most recently, EPA proposed adding 300 new chemicals to the list, nearly doubling it. Many of these do not meet Congress's criteria, and CMA opposes the wholesale expansion.