Chemical industry information reporting, Sections

At the same time, however, there is emerging evidence that PMN requirements have significantly inhibited innovation in the chemical industry. Section 5 has inevitably had some impact on innovation, and EPA regulations that add to the basic statutory requirements are likely to impose burdens on the chemical industry that are unnecessary. That is why CMA recommends that the Agency, at a minimum, limit those regulations to the clear requirements of the statute. Requirements such as supplemental reporting of PMN information, mandatory consumer contacts, advance substantiation of confidentiality claims, and the "invalidation" of incomplete PMNs, will only serve to increase the costs of a process that already imposes substantial burdens. Since EPA can adequately protect human health and the environment without these requirements, they should be eliminated. 

Other provisions of SARA basically reinforce and/or broaden the basic statutory program dealing with the releases of hazardous substances (CERCLA, Section 313). It requires owners and operators of certain facilities that manufacture, process, or otherwise use one of the listed chemicals and chemical categories to report all enviromnental releases of these chemicals annually. This information about total annual releases of chemicals from the industrial facilities can be made available to the public. 

Some limitations should be considered when interpreting the present results. This kind of questionnaire does not allow for confident causal conclusions. There were no means to externally validate the responses of the questionnaire. The present results, therefore, may be subject to potential inaccuracies related to the inability of respondents to recall information correctly. First, the main limitation of the current study is its cross-sectional nature. Second, this study exclusively relies on self-report measures. Third, the cross-sectional nature of the survey did not allow for the determination of causal relationships. Fourth, the generalizability of the findings should be taken with caution, as the study was conducted within the dimensions of the Finnish chemical industry. Fifth, longitudinal studies will be needed to establish the causality of the relationships. One cannot be certain that the namre of the responses to the questionnaire would be the same in different countries. The potential lack of measurement calibration would likely have an impact on the relationships between measures as reflected in correlations and regressions. 

Production, Import/Export, Use, Release, and Disposal. According to the Emergency Planning and Community Right-to-Know Act of 1986, 42 U.S.C. Section 11023, industries are required to submit chemical release and off-site transfer information to the EPA. The Toxics Release Inventory (TRI), which contains this information for 1996, became available in May of 1998. This database will be updated yearly and should provide a list of industrial production facilities and emissions. However, hydrogen sulfide is not required to be reported under the TRI. 

Section 8(e), which requires industry to notify the EPA Administrator if it obtains information indicating that a substance presents a substantial risk, has been a fertile source of information about chemical hazards. More than 400 substantial risk notices have been filed. However, the connection between information and action is unclear with respect to the notices. I do not know of any action, either regulatory or voluntary, by either industry or EPA, that has been taken as a result of an 8(e) notice. Undoubtedly, there have been some industry actions. The apparent lack of attention by the government is more troublesome, and the recent "100-day report" by OTS identifies the need to make response to 8(e) notices a matter of higher priority. 

This section of this paper reports on a detailed study of the organic compounds in the Delaware River. Since most of our previous studies have dealt with isolated chemical plants on small rivers, we felt it would be instructive to study a complex river system surrounded by several large-scale chemical manufacturers. This would give us information on the effluents from several industrial dischargers, the relative persistence of chemical discharged from any single source, and the movement of these industrial chemicals in a major river ecosystem. 

Only chemicals that are considered relevant within the scenario of the proficiency test are to be reported to avoid irrelevant chemicals being reported, in real off-site sample analysis, confidential information on the facility under inspection is revealed (e.g. information on an industrial production process that is not relevant to the implementation of the CWC). This requirement is a consequence of Paragraph C.17 of the Confidentiality Annex of the CWC, l1. The reporting of irrelevant chemicals is penalized with immediate failure of the test see Section 6.1. 

EPCRA s primary purpose is to inform citizens of chemical hazards in their communities. Sections 311 and 312 of EPCRA require businesses to report the locations and quantities of chemicals stored on-site to State and local governments in order to help communities prepare to respond to chemical spills and similar emergencies. EPCRA Section 313 requires the US Environmental Protection Agency (EPA) and the States to annually collect data on releases and transfers of certain toxic chemicals from industrial facilities, and make the data available to the public in the Toxics Release Inventory (TRI). 

Section 313 of EPCRA authorizes the USEPA s Toxic Release Inventory (TRI), a publicly available database that contains information on toxic chemical release and waste management activities reported annually by certain industries as well as federal facilities. The USEFA issues a list of industries that must report releases for the database. To date, the USEPA has not included oil and gas extraction as an industry that must report under the TRI. This is not an exemption in the law rather, it is a decision by the USEPA that this industry is not a high priority for reporting under the TRI. Part of the rationale for this decision is based on the fact that most of the information required under the TRI is already reported by producers to state agencies that make... 

---