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Toxics Watch 1995: Executive Summary

More than 72,000 different chemicals are circulating through the US economy. Each year, nearly 6 trillion pounds of these chemicals are produced, and they play a role in plastics, adhesives, semiconductors, fuels, dyes, and other products. In this country, 24,000 manufacturing plants that are subject to federal reporting requirements reported that they had generated more than 37 billion pounds of chemical waste in 1992.

Toxics Watch 1995 inaugurates a series of reports, grounded in data analysis, that will provide a comprehensive examination of the state of knowledge regarding environmental toxic chemical problems and solutions. The goal of these reports is to help US leaders and citizens address toxic chemical problems more effectively. Toxics Watch 1995 provides:

• an assessment of the most significant sources of toxic contamination at sites that range from the human body and the Great Lakes to US hazardous waste sites and the stratospheric ozone layer
• the first listings of the 100 companies that generate the greatest quantities of production-related toxic chemical wastes, carcinogens, and ozone-depleting chemicals in the United States
• the first overview of inventory data compiled under the Toxic Substances Control Act (TSCA) on the production of synthetic organic chemicals in the United States
• the first breakdown of how individual companies are managing their wastes, including a breakdown of which companies are moving most rapidly away from disposal, the least environmentally sound strategy
• an assessment of what is known about US companies' progress towards preventing pollution
• the first analysis of the quality of US Environmental Protection Agency databases' coverage of toxic chemical production, use, and movement through our economy
• three special-feature chapters that examine the environmental justice movement; the EPA's 33/50 program, which seeks voluntary corporate efforts to reduce transfers and releases of 17 key chemicals; and state data collection systems that go beyond federal reporting requirements.

Toxics Watch's Focus on Pollution Prevention: The Surest Way to Avoid Toxic Contamination

Cleaning up the environment after toxic chemical contamination occurs is, at best, difficult and costly. At worst, it is an impossible task. There are not enough dollars in the US economy to resolve all the contamination problems resulting from industries and products. To clean up or even stabilize contaminated hazardous waste sites in the United States may cost as much as 1 trillion dollars. Cleansing the Great Lakes completely of their many toxic contaminants or clearing the stratosphere of ozone-depleting substances seems inconceivable at any expense.

Another way of approaching toxic substances in the environment is to isolate people from contact with the environment - for example, declaring a waterway off-limits for fishing, swimming, or drinking. This can be done quickly, costs far less than cleanup, and offers much greater certainty of success. But isolation strategies can deny people the enjoyment of their environment. In addition, isolation usually provides no ecological protection and does not lead to environmental restoration, so problems are passed on to future generations.

Only one approach to toxic chemical contamination is relatively inexpensive to implement and saves money, and that is to prevent pollution in the first place. Pollution prevention, also known as source reduction, pays industry back in improved industrial efficiency; leads to better process and product consistency; eliminates the need for costly environmental remediation; and reduces health and environmental risks with greater certainty than any other method. This approach also avoids ecological damage and preserves the environment, intact, for generations to come.

Business, government, and environmental leaders now agree that preventing waste at the source is the superior strategy. The unanimously passed federal Pollution Prevention Act of 1990 declares that "source reduction is fundamentally different and more desirable than waste management and pollution control."

According to the Pollution Prevention Act, if pollution is not prevented, it should be recycled in an environmentally sound manner; in the absence of feasible prevention and recycling opportunities, pollution should be incinerated to recover energy or treated. Disposal of waste or its release into the environment should be used only as a last resort.

Risk assessment and cost-benefit analysis of toxic contamination are valuable tools for prioritizing programs focused on waste that has already been created. But such analyses are costly themselves and are often inconclusive. On the other hand, putting more effort into prevention avoids both future risks and future costs.

Because of all the benefits that pollution prevention provides, the analyses in Toxics Watch 1995 focus on the extent to which US industry is implementing or failing to implement pollution prevention measures.

Major Findings of Toxics Watch 1995

• Publicly available data provide no clear quantitative picture of US chemical production, use, or presence in the environment.
• Despite gaps in available data, it is clear that the volume of toxic chemicals used in commerce in the United States is huge: about 6 trillion pounds per year, with production increasing.
• Confidential business information claims allowed under federal law are broad and interfere with the public's ability to properly interpret data that is publicly available.
• Toxic chemicals dispersed to the environment through the use of commercial products are a significant source of environmental contamination, in some settings comprising the predominant source of contamination.
• Chemicals brought into commerce before 1979, when the US Environmental Protection Agency (EPA) began its review of new chemicals under the Toxic Substances Control Act, constitute more than 99.9 percent of current production. These chemicals are marketed with few restrictions on use and account for most of the growing volume of chemical production.
• Data from the US Toxics Release Inventory (TRI) show that, despite significant achievements by individual facilities and some smaller industries, there is no overall national reduction in toxic waste generation by the 24,000 plants that report to TRI. Overall, there has been a net increase in TRI waste generated since 1991. TRI data show that production-related generation of specific chemical waste increased 3 percent between 1991 and 1992. Data reported to the Resource Conservation and Recovery Act's Biennial Reporting System (BRS) show that generation of BRS toxic waste increased 9 percent between 1989 and 1991.
• Neither the TRI nor the BRS waste-tracking systems allow measurement of the quantity of toxic chemicals in waste reduced by source reduction.
• The data reported by some companies reputed to have made great strides toward waste prevention do not show such results.
• Massachusetts and New Jersey, both of which collect data that go beyond that required for the federal TRI, each collect a set of data that permit a much clearer picture of toxic chemical use than do the data collected by TRI. In both states, chemical, industrial, and geographical distribution is revealed to be very different with respect to use of chemicals than it is for either waste generation or environmental releases and transfers.

Toxics in the Environment: A Dearth of National Information

Knowing the ambient concentrations of chemicals in our air, water, soils, or biological species is vital. Such information enables us to identify those chemicals most likely to cause health and environmental problems and to measure ecosystem exposure. This information provides an important, although imperfect, predictor of human exposure.

After six months of searching chemical concentration databases, Toxics Watch 1995 found that the available data could not supply basic answers regarding national or regional concentrations of chemicals in our environment:

• Because of the databases' limitations, it is not possible to draw, with confidence, any nationwide conclusions about contamination of the ambient environment by toxic chemicals.
• Databases on chemical releases, while valuable for understanding waste released from manufacturing facilities, are of little use for predicting national or regional concentrations.
• While hundreds or perhaps thousands of databases contain information on toxic chemicals in the environment, Toxics Watch 1995 identified fewer than a score that are both national in scope and broad in coverage of toxic chemicals. Few of those are current and non-duplicative.
• The few databases that are national in scope and that cover a large set of toxic chemicals contain comparatively few measurements on many of those chemicals. Toxics Watch found that particular chemicals too often have been measured at only a tiny fraction of sites and/or on a few occasions.
• The lack of consistency in public databases' monitoring methods and in conditions monitored results in uncertainty about any particular portion of the data; long-term trend analysis is unreliable.

Air

• A huge amount of information is available on the chemical substances for which National Ambient Air Quality Standards (NAAQS) have been set - carbon monoxide, lead, nitrogen dioxide, ozone, and sulfur dioxide. Detailed time-trend data are available on a local, regional, and national basis. Publications and computer tools make these data readily accessible.
• There is no such consistent data collection with regard to other toxic chemicals in air. The data that have been collected do not support any national conclusions for chemicals other than those that are the subject of NAAQS.

Water

• EPA's STORET database contains a Water Quality System (WQS) with information for 800,000 sampling sites on approximately 14,000 water quality parameters and reports data on approximately 2,500 discrete chemicals. Most of this information, collected to meet local needs, is of uneven or unknown quality and consistency; it is not useful for making reliable assessments of broad regional or national water quality.
• The US Geological Survey's nationwide system of several hundred stations monitor water quality, with nationally consistent measurement and reporting, and these data are available in WQS. This very small subset of WQS data is suitable for evaluating water conditions on a nationwide basis.

Land

• There is no national database on contaminants in soil comparable to those for air and water. The most complete, consistent database on soil contamination comes from investigations of the highly contaminated soil found at Superfund sites. This database, known as CARD (Contract Laboratory Program Analytical Results Database), is maintained by EPA's Office of Solid Waste and Remedial Response and contains information from hundreds of sites on the majority of the toxic chemicals in the search set. Because of the nature of site selection and sampling strategy, these data are not broadly representative of national conditions and cannot be used to investigate temporal trends.

Toxics in Commerce: Huge Volumes, Scant Information and Regulation

Few data resources provide a quantitative description of the conditions and trends of toxic chemicals in commerce. Focusing on chemicals that are subject to EPA review under the Toxic Substances Control Act (TSCA), Toxics Watch 1995 finds:

• More than 13 million chemicals have been characterized and reported on in the scientific literature. An additional 685,000 chemicals are identified each year. Many chemicals present in nature remain unidentified.
• There are more than 72,000 chemicals in commerce in the United States, excluding foods, drugs, cosmetics, and pesticides. Each year, as reported to EPA, nearly 6 trillion pounds (5,905 billion pounds in 1989) of organic chemicals are manufactured in or imported to the United States.
• Thousands of chemicals in commerce are of undefined or variable composition. Their environmental and health hazards are often undefined as well.
• Almost none of the 72,000 chemicals in commerce in the United States have been fully characterized for their ability to cause environmental and health effects.
• No clear picture of US chemical production or use can be obtained. The paucity of data on the manufacture and use of chemicals makes quantification impossible. With no database providing the public or the government with a national overview, it is also not possible to track product stewardship efforts by companies or facilities.
• Only a portion of the chemical production and use information that can be found in government databases is available to the public - how much is uncertain. Industry submits much of its data with claims of confidentiality, and those data are withheld from the public.

New Chemical Review: Tiny in Scope, Effective Where Used

Preventing toxic substances from entering commerce presents the best prospect for addressing the environmental and health concerns they raise. Potential risks are difficult to address once toxic chemicals enter the market. The more fully integrated a chemical is into the economy, the more complex are both the regulatory task of removing it from use and the industrial task of identifying and introducing less harmful substitutes. Only two categories of chemicals, polychlorinated biphenyls (PCBs) and chlorofluorocarbons (CFCs), have been targeted for phase-out from commerce to date.

• Each year, EPA receives proposals for manufacture or import of about 1,500 new chemicals. New chemicals enter commerce through manufacture or import at the rate of about 500 ­ 1,000 per year.
• EPA's program for reviewing new chemicals before they come into production, begun under TSCA in 1979, is effective in establishing numerous restrictions to protect health and the environment. Since 1979, more than half of the chemicals proposed for manufacture have been withdrawn or have not yet been introduced into commerce. EPA has taken more than 800 regulatory actions that in some way restrict the use of chemicals that have been proposed; this compares with just two actions restricting the manufacture of chemicals already in commerce (PCBs and CFCs).
• Chemicals brought into commerce before TSCA review began in 1979 constitute more than 99.9 percent of all production, and they are marketed with few of the type of restrictions on use that apply to new chemicals reviewed by EPA. Moreover, these pre-existing chemicals account for most of the growth in chemical production.

Sources of Environmental Toxic Contamination: Products' Role Underestimated

"End-of-the-pipe" pollution control programs limit releases of certain chemicals to the environment from identifiable industrial sources and from other controllable sources, such as automobiles. Such programs reduce certain kinds of pollution to a degree. But whole other source areas of environmental chemical pollution have hardly been addressed, including non-point sources (such as urban and agricultural storm runoff) and chemicals dispersed to the environment through the use of commercial products.

Toxic Watch's analysis of sources of environmental contamination relies on studies of a number of contaminated settings, including the human body, sites in the Great Lakes region, US Superfund sites, and the stratospheric ozone layer - sites chosen because they have been the focus of extensive study. While these studies are helpful in characterizing sources of toxic chemical pollution, they are by no means comprehensive or definitive. They point strongly to the following findings:

• Without in any way diminishing the seriousness of the problem of toxics in industrial waste, the role of product use as a source of chemical contamination was found to be significant and in some cases predominant in the settings covered by Toxics Watch 1995. In some cases, such as lead, indoor air toxics, and ozone depletion, products are the primary source of the problem; in other environmental settings, such as the Black River Watershed in Ohio, their role is secondary to industrial process waste, but still significant.
• Examining some specific environmental settings turns up some counter-intuitive results about the role of product use, such as:
  • For many people, indoor air pollution is a more dangerous source of toxic contamination than outdoor air pollution.
  • The materials in municipal landfills in many cases are at least as hazardous as those in industrial landfills.
  • In the cases of both indoor air and municipal landfills, the presence of toxic chemicals stems primarily from the intentional use of toxic chemicals in widely distributed commercial products.
• Even when the environmental setting itself is generally perceived as industrial - for example, many Superfund sites - much of the contamination there may arise from the use and disposal of commercial products.
• Toxics Watch's analysis of Superfund sites in three states found that contamination of 18 of 36 sites was attributable primarily or in part to commercial product use and disposal, not industrial process waste. A Texas A & M study of 58 landfills found that of 143 toxic chemicals found, 60 were found in municipal waste samples, 31 in industrial waste landfills, and 39 in both.
• The impact of pollution arising from product use is particularly significant when assessing the total burden in a human body of a particular toxic chemical or group of chemicals. The cumulative effects of exposure through product use create hidden hazards that are difficult for the individual to avoid.
• EPA's estimates of cancer risks from various sources of air pollution provide approximate information on the relative importance of product use and industrial process wastes for this category of contamination. The data show that product use may contribute substantially more to this cancer risk - between 54 and 90 percent of the total risk from all sources considered by EPA - than do production wastes, which contributed between 3 and 25 percent.
• Releases of ozone-depleting chemicals to the atmosphere occur during their manufacture, during the manufacture and processing of products containing ozone depleters, and throughout the period of product use and disposal, in some cases for several decades. While the amount of ozone-depleting chlorofluorocarbons (CFCs) released from use in an individual product may be small, cumulative effects may be substantial. An automobile air conditioner releases only about 400 grams of CFCs each year, but there are 140 million air-conditioned vehicles on the road in the United States alone. This translates into total annual releases from US vehicles of 125 million pounds.
• Studies of large geographic settings, including the Great Lakes region, reveal contamination resulting from all three categories of toxic chemical sources (industrial process waste, commercial product use, and natural causes), but knowledge of these sources is very incomplete and much pollution remains unaccounted for. Less than 1 percent of the lead that enters Lake Ontario from the Genesee River can be traced to permitted discharges to that river; the remaining 99 percent comes from sources that are difficult to measure, including airborne emissions from motor vehicles and incinerators and urban stormwater runoff.

Toxics in Waste

The Pollution Prevention Act of 1990 (PPA) established a national policy of preventing pollution or reducing waste at its source. According to the Act, source reduction "reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment...prior to recycling, treatment, or disposal." This policy is part of the broader concept of an environmental management hierarchy in which source reduction should be considered first so that waste is not generated. Once waste exists, waste management options in priority order include: recycling, incineration with energy recovery, and treatment. Release - disposal to the environment - is the last and least desirable option.

The best sources of national information about pollution generation and prevention are the Toxics Release Inventory (TRI) and the Resource Conservation and Recovery Act (RCRA) Biennial Reporting System (BRS).

Toxics Watch 1995's analyses of TRI and BRS data show that:

• Generation of toxic waste increased between 1991 and 1992, as reported to TRI, and between 1989 and 1991, as reported to BRS, the latest reporting years of data available for this report.
  • TRI production-related waste increased by 3 percent between 1991 and 1992, from 36.3 billion pounds to 37.3 billion pounds. More facilities showed decreases between the two years than increases, but the size of the average increase exceeded the size of the average decrease. Facilities have projected a further increase in production-related waste of 0.3 percent by 1994 from 1992 levels.
  • Generation of BRS toxic waste increased 9 percent between 1989 and 1991, from 482.6 billion pounds to 526.3 billion pounds. These figures represent those toxic waste codes reported in both years. Additional toxic waste codes were added for 1991 reports, and these new codes generated an additional 421.9 billion pounds of toxic waste.
• Neither TRI nor BRS allows clear measurement of changes in specific chemical waste generation that result from source reduction.
• There is no way of analyzing the relationship between quantities of waste avoided through pollution prevention and production levels, based on currently available data. What is known is that, despite source reduction efforts, toxic waste generation continues to rise and every pound of toxic waste generated adds an increment of risk to the total. There will be no way to correlate increased waste generation with production levels unless and until companies provide specific data on the pounds of chemicals they avoided creating through source reduction initiatives.

Increased production need not result in more production-related waste (in fact, new production processes may provide the opportunity to make operations much more efficient and less waste-intensive). Increases in production-related waste at TRI facilities reporting source reduction activity were one-fourth as large as increases in production-related waste at TRI facilities reporting no source reduction.

• Of facilities reporting on toxic waste to BRS, 51 percent reported undertaking source reduction alone or in conjunction with recycling. However, these source reduction activities applied to only 7 percent of the toxic waste streams tracked by BRS and reduced the total amount of toxic waste generated by just 2 percent. One-third of the total national reduction reported to BRS was reported by just one reporting facility.
• Of facilities reporting to TRI, 36 percent reported implementing some source reduction activities. However, the amount of total production-related waste at these facilities decreased by less than half of one percent between 1991 and 1992.
• Facilities reporting some level of source reduction activity not only generated less waste, but also managed the waste they did generate more responsibly than facilities that did not report any source reduction. TRI facilities reporting some pollution prevention recycled more of their waste, released less waste to the environment, and sent less waste to treatment and disposal facilities than companies that did not report undertaking any pollution prevention activities. In contrast, facilities that did not report source reduction efforts showed an increase in the quantity of waste released to the environment and sent off site for treatment and disposal.
• TRI facilities report an overall movement toward more desirable waste management options. Recycling is the most widely used management option reported to TRI and is projected to increase: 52 percent of production-related waste was managed by recycling in 1992, and facilities expect that to rise to 55 percent by 1994.
• Release to the environment and off-site transfer to disposal, the least environmentally sound waste management options, were still used to deal with 9 percent of production-related waste in 1992, TRI facilities reported. These facilities expect that figure to decline to 7 percent by 1994.
• Out of 23,630 facilities reporting to TRI in 1992, the top 50 (those reporting the largest amounts of production-related waste) represented only 0.2 percent of the total number but accounted for 43 percent of all such waste. Hence, both the practices of these facilities and the way in which they are reporting waste management activities are of paramount importance in getting a clear picture of TRI production-related waste.
• For 1991, just 50 facilities generated 71 percent of all RCRA toxic waste reported to BRS.
• Of the five facilities reporting the largest increases and the five reporting the largest decreases in production-related waste to TRI for 1991-1992, six achieved their losses or gains through reclassifying waste management activities (especially recalculating on-site recycling as part of the manufacturing process). Toxics Watch 1995 discovered that two other facilities made reporting errors that the facilities themselves later confirmed. These ten facilities reported a 292-million-pound increase and a 431-million pound decrease in production-related waste.
• Only 25 facilities are responsible for the majority of increases in TRI waste from 1991 to 1992. While the average TRI increase per facility was 405,000 pounds, increases at these 25 facilities alone averaged 68.4 million pounds.
• It appears that undertaking of source reduction activities as reported to TRI was also associated with a decrease in waste generation. While total production-related waste for all chemicals increased by 3 percent, waste associated with TRI forms reporting source reduction decreased 0.3 percent, compared with a 4 percent increase in waste associated with forms that did not report source reduction.

Chemicals in Waste

• Most patterns of waste management and of environmental distribution for chemical classes are consistent with their common chemical and physical properties (e.g., nonflammable metals are seldom sent to energy recovery facilities and volatile ozone depleters are mostly released to the air). The relative cost of the chemicals is also a factor.
• 81 percent of production-related waste for metals was managed by recycling in 1992. Metals do not burn and so cannot be used for energy recovery, and regulations restrict their release and disposal. In addition, metals are relatively expensive as raw materials when compared to other chemical classes.
• Recycling accounted for 53 percent of production-related waste associated with acids/bases/salts in 1992, and treatment for another 41 percent of this waste category. These chemicals are generally inexpensive and easily recycled or treated, but usually do not burn and have restrictions on their release and disposal.
• 98 percent of 1992 releases and disposal of halo-organic chemicals emerged as air emissions, consistent with their uses as solvents and their relatively high volatility.
• 46 percent of 1992 production-related waste for non-halogenated organic chemicals was managed by recycling, and an additional 22 percent was managed by energy recovery - the highest percentage of waste management by energy recovery among the chemical classes in this report. This high percentage occurred because most of these chemicals burn well.
• Among the three groups of chemicals that Toxics Watch 1995 analyzed separately, carcinogenic chemicals showed an increase in production-related waste between 1991 and 1992, while ozone-depleting chemicals and chloro-organic chemicals showed a decrease.
• The decreases reported in production-related waste for ozone-depleting, halo-organic, and chloro-organic chemicals are consistent with reported source reduction activities: these three categories showed greater percentages of forms reporting source reduction activities in 1992 than the other chemical classes and groups. More than 40 percent of the forms for ozone-depleting, halo-organic, and chloro-organic chemicals report undertaking source reduction activities in 1992. The average for all TRI chemicals was 25 percent.

Toxics in Waste by Industry

A number of highly publicized company and industry initiatives have created programs to limit waste generation as well as to reduce environmental release and disposal, and these programs go well beyond compliance with environmental regulations. Companies and industry groups with such initiatives include Dow Chemical, Du Pont, Monsanto, and the Chemical Manufacturers Association's (CMA) Responsible Care program. Responsible Care encourages member companies to establish and maintain priorities, goals, and plans for waste and release reduction. Responsible Care also requires that preference be given first to source reduction, second to recycling and reuse, and third to treatment as a means of accomplishing these reductions. If successful, such initiatives should, over time, have an important impact in reducing toxics in waste.

An analysis of the most recent data shows that in the aggregate, no net reduction occurred in waste generation of TRI chemicals from 1991 to 1992, nor is any projected in the next two years. Some facilities, companies, and smaller industries are achieving significant reductions, but their reductions between 1991 and 1992 are more than offset by the lack of accomplishments of the others.

On the other hand, aggressive source reduction at major facilities in key industries could have a significant impact on the aggregate national toxic waste picture: analysis of the most recent TRI and BRS data shows that a few industries and facilities dominate toxic waste generation.

The 1992 TRI data and the 1991 BRS data reveal the following on an industry-by-industry basis (with industry groups defined by their SIC codes):

• The chemical industry's toxic waste volumes are so large compared with the other manufacturing industries reporting to TRI that this industry dominates nearly all TRI statistics on the generation of production-related waste. The chemical industry generated 19.9 billion pounds of TRI waste in 1992 - more than half of the 37.3 billion-pound total. It also generated 69 percent of all carcinogens in TRI waste. The industry's recycling figures alone account for almost one-third of all TRI production-related waste. Two chemical plants, First Chemical Corp., in Pascagoula, Mississippi, and Goodyear Tire & Rubber, in Beaumont, Texas, reported a third of the industry's and 18 percent of the nation's total production-related toxic waste because of the methods by which they calculate on-site recycling. The primary metals industry reported the second largest amount of production-related waste to TRI (4.0 billion pounds).
• In the 1991 BRS data, the chemical industry also reported more RCRA toxic waste generation (388.6 billion pounds) than any other industry. The petroleum industry reported the second largest amount (270.9 billion pounds) to BRS.
• Although 23,630 facilities reported on production-related waste to TRI in 1992, waste generation is concentrated within relatively few facilities for most industries. The five facilities with the largest amount of production-related waste within each industry group together contribute 36 percent of the total production-related waste for all industries. A single R.J. Reynolds facility in Winston-Salem, North Carolina, reported 92 percent of the entire tobacco industry's production-related waste to TRI in 1992.
• The waste generation reported to BRS was even more concentrated in a few facilities than the production-related waste reported to TRI. In 1991, just 17 out of 22,344 facilities reported more than 50 percent of all the RCRA toxic waste generated.

Geography and Waste

Toxics Watch 1995 examines waste generation and the environmental management of waste nationally, by state and county, to provide examples of the types of geography-driven analyses that can be done at this level with TRI and BRS data. Other types of geographic analyses, which are likely subjects of future Toxics Watch reports, include: analyses on a watershed or air-shed basis; co-analyses with demographic data; and analyses of facilities upwind or upstream of the political jurisdictions their emissions affect.

Although every state has both TRI and BRS facilities within its borders, facilities generating the largest amounts of toxic chemicals are concentrated in only a few states. TRI reports for 1992 and BRS reports for 1991 document clearly that Texas and Louisiana continue to be the states with the largest amounts of toxic waste.

• Facilities in Texas and Louisiana reported the largest increases in total TRI production-related waste from 1991 to 1992, while facilities in Georgia and New Jersey reported the largest decreases.
• Releases and transfers of TRI chemicals remain concentrated in relatively few of the approximately 3,000 counties in the nation. The 100 counties with the largest amount of releases and transfers accounted for 60 percent of the national total in 1992.
• Generally, rankings and changes in the RCRA waste generation data are due to single facilities, because the 50 facilities reporting the largest amounts of toxic waste generated to BRS accounted for 72 percent of all BRS toxic waste. Sixteen of these facilities are located in Texas.

A Toxics Watch 1995 Feature: Materials Use Accounting and Pollution Prevention in New Jersey and Massachusetts

Massachusetts and New Jersey collect information from facilities in their states that goes beyond the data required for the federal Toxics Release Inventory (TRI). How useful is this additional information in understanding more fully the risks of a toxic chemical at a facility, how toxic chemicals are used, the amount of toxic chemicals in commerce, and the amount of source reduction of toxic chemicals in industrial waste? The Massachusetts and New Jersey systems differ from one another both in the type of information collected and because there is a very different mix of industries in New Jersey as compared with Massachusetts:

• While the data collected by New Jersey and Massachusetts are different, both permit a much clearer picture of toxic chemical use than does the data collected for TRI; both require reporting inputs to the production process in addition to a fuller depiction of outputs. In both states, chemical, industrial, and geographical distribution is revealed to be very different with respect to use of chemicals than it is for either waste generation or environmental releases and transfers.
• New Jersey offers the most complete picture of the flow of a chemical into a facility, through the facility's processes, and into the facility's waste and product outputs. This picture provides perspectives completely lacking from the TRI data for the same facility - including a perspective on the potential risks posed in the workplace and during the transport of toxic materials.
• Massachusetts offers the most complete picture of the conditions of use of the chemical at a facility, obtaining a description of each process (production unit), the range of amount of chemical use, and the percent change in waste by process, instead of facility-wide as in New Jersey.
• In contrast to the federal TRI, where only data on the amount of chemicals in waste and in releases and transfers are reported, both New Jersey and Massachusetts require data on how much of a toxic chemical is shipped as or in products from the facilities. For New Jersey, of the toxic chemical inputs to the manufacturing process (20.0 billion pounds), 34 percent (6.7 billion pounds) ends up as waste, and this is the amount reported to the TRI. In addition to the TRI data, New Jersey facilities reported to the state that 2.8 billion pounds (14 percent) were consumed during the manufacturing process and 10.7 billion pounds (54 percent) were shipped in products. Massachusetts facilities reported a total of 1 billion pounds of toxic chemicals used, with 14 percent ending up as waste (by-product) and 42 percent shipped in products. Such data are valuable because toxic chemicals in products pose as large or larger environmental threats than industrial wastes, yet much less information is available about toxics in products.
• Only New Jersey requires the reporting of source reduction quantities, and the New Jersey data yield the clearest picture of how much source reduction is actually occurring. The reasons for changes in waste generation from one year to the next are much clearer in the New Jersey data than in TRI, because New Jersey requires facilities to report the specific amount of individual chemicals in waste reduced due to source reduction activities, the amount of individual change due to discontinuation of use or relocation of the process to another facility, and changes in production level.
• Despite much fanfare by government and industry, source reduction of industrial toxic waste is not occurring to any appreciable extent in New Jersey. In fact, the trend is in the wrong direction: fewer facilities reported any source reduction activity in 1992 than in 1991, and the amount of source reduction they reported was both a smaller amount and a smaller percentage of waste generation.