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Tracking Toxic Chemicals: Executive Summary

Since the emergence of the US chemical industry in the mid-1940s, the manufacture and use of chemicals in the nation has steadily risen as industry turns to synthetic chemical compounds to make the products on which modern commerce and consumers depend. The way of life made possible by the manufacture of new chemical products includes features of safety, comfort, and convenience that would not have been feasible 50 years ago. The benefits of products such as refrigerants, pharmaceuticals, and plastic protective gear are clear to the millions of people who rely on them. Much less clear is the extent to which the use of chemical constituents in these and other commercial and consumer products pose risks to human health and the environment - whether during manufacturing, product use, or disposal.

More than 77,000 chemicals have been in "commerce" since 1979, meaning they have been manufactured in or imported to the United States. In the only such analysis ever performed in the United States, the National Research Council (NRC) estimated in 1984 that toxicity information, often minimal, was only available for about 20 percent of the chemicals in commerce at that time. Based on its statistical sample, NRC further concluded that none of these chemicals' health and environmental risks had been adequately characterized.

Indeed, a number of chemicals have been found, sometimes only after years of use, to cause serious health and environmental problems. For example, the harmful properties of lead and mercury on the human nervous system have been known for centuries, but only recently has science recognized that exposure to these and other chemicals, such as dioxin, can cause harm - even at very low exposure levels. Knowledge of the effects of many other chemicals have come as a series of particularly nasty surprises. For instance, DDT accumulates in the food chain, threatening reproductive health of a range of species, along with DDE, the more potent chemical to which it decomposes over time.

How can we begin to address the potential risks posed by these tens of thousands of substances circulating in our workplaces, communities, and homes? The current approach authorizing the United States Environmental Protection Agency (US EPA) to regulate toxic chemical use places the burden on US EPA to prove that a chemical poses an "unreasonable" risk to humans and the environment. Yet the basic information required to meet this burden of proof - adequate information on toxicity and exposures - does not exist for the vast majority of chemicals in commerce, and US EPA does not have the capacity to collect this information.

Given the limitations of this approach, which assumes that chemicals are "safe until proven dangerous," a more protective strategy would seek to reduce or eliminate potentially harmful exposures, even in the absence of extensive toxicity information. The first step to avoiding these exposures is to identify where and how chemicals are being used. Making information on industrial chemical use publicly available would engage a wide range of stakeholders - including manufacturers, policymakers, workers, health care providers, consumers, and communities - in identifying routes of exposure, potential problems caused by these exposures, and solutions.

Nowhere in the United States is all of this information collected in a comprehensive and publicly accountable manner. On the national level, industrial facilities that 1) manufacture or process a reportable chemical in quantities of more than 25,000 pounds per year, or 2) use more than 10,000 pounds of a reportable chemical per year must report their annual releases and transfers to the federal Toxics Release Inventory (TRI) if it is one of the roughly 600 toxic chemicals listed by TRI. New Jersey is one of only two states in the nation that requires the same facilities that report to TRI to provide more data on chemical use. New Jersey requires industrial facilities to report quantities of chemicals flowing through facilities. This includes chemicals that: have entered the facility; were used and consumed in the process (inputs); have left the facility in waste (released to air, water, land, and off-site transfers); and that have left as (or in) a product (outputs). This reporting system of the chemicals moving through a facility is known as materials accounting data (refer to Figure 1 on page 3 for a graphic comparison of TRI and materials accounting data).

New Jersey's materials accounting database came out of the 1984 Worker and Community Right to Know Act (NJRTK), which was the first law of its kind to require industrial facilities to publicly report quantities of toxic chemicals transported in and out of facilities as (or in) products, chemically converted in production processes, stored on site, and generated as waste and subsequently released to the environment or transferred off site for recycling, treatment, and disposal. Following New Jersey's lead, Congress passed the federal Emergency Planning and Community Right to Know Act (EPCRA) in 1986, marking the emergence of the "right to know" as national policy. Under EPCRA, the Toxics Release Inventory was created.

In Tracking Toxic Chemicals: The Value of Materials Accounting Data, INFORM takes a close look at the materials accounting data collected in New Jersey and its utility as a mechanism for tracking industrial toxic chemical use and product shipments. While New Jersey does not collect all of the information needed to systematically identify exposure reduction opportunities and track progress, INFORM has found that the information contained in the state's database allows for three types of analyses that would not be possible with TRI data alone:

• Tracking quantities of industrial toxic chemicals used. Materials accounting data provide information on the amount of specific industrial toxic chemicals imported to, consumed, produced, shipped off site as product, or stored at industrial facilities in New Jersey. Recording the total quantity used of a given chemical at a facility in one year can show whether all uses of that chemical have been accounted for. Tracking all uses is an important step toward describing their associated exposures, because while certain contained uses or immediate chemical conversions may not result in exposures, other dispersive applications (such as spraying) may expose workers and the local environment.
• Evaluating the reduction of industrial toxic chemical use and waste at the source. Only New Jersey requires industrial facilities to report on any reductions achieved in the use of toxic chemicals or the generation of waste through pollution prevention measures, compared with the previous year. Reducing the use of toxic chemicals at an industrial facility and the generation of waste is the most direct way of eliminating human or environmental exposure that might occur during handling, storage, recycling, treatment, disposal, or release to the environment.
• Assessing the efficiency of industrial toxic chemical use. Materials accounting data allow a variety of measures of how efficiently a facility is using particular chemicals. From an environmental standpoint, using a chemical more efficiently during manufacturing would mean that more of the total amount used goes to its intended purpose (such as an ingredient in a product, a processing aid, or a reagent) and less is generated as waste. (Efficient material use as defined here might also be the most cost-effective way of using the given material, but this is not necessarily the case in all situations.) New Jersey's data can be used to shed light on those facilities that should be recognized for improvements already achieved or that might be targeted for technical assistance due to lack of evidence of such improvement.

For industry, government, communities, and public interest groups concerned about the use of chemicals at industrial facilities, the availability of materials accounting data can bring significant benefits.

• Businesses can plan better. Businesses can use the data to identify opportunities for preventing waste and measure their own performance over a specific period of time. In particular, businesses can examine the efficiency with which they are using chemicals, not just in terms of waste generation but also whether the chemical is used for its intended purpose or whether it is ending up in a product when it does not need to be there. In addition, companies can compare the performance of their facilities to similar facilities owned by other companies.
• Government can target regulatory programs more effectively. Government can use the data to identify which chemicals are used in the largest quantities and in the most inefficient manner; government can also use the data to identify which facilities or industrial sectors are responsible for these uses. From a regulatory or programmatic standpoint, this information would assist in targeting chemicals for reduction and in targeting facilities or communities for technical assistance. In addition, government agencies responsible for public health can use the data to track what chemicals are leaving facilities as (or in) products and to evaluate the potential links between these uses and adverse health effects over time.
• Communities can identify local problems and promote constructive change. Communities in the neighborhoods of industrial facilities can examine the data to track quantities of chemicals entering and leaving the facilities. The data will also provide public interest groups studying industrial activity with a new set of questions to raise with companies, such as: why is this toxic chemical being shipped as part of this product, when the company reports that this chemical was not intended to be part of the product?

As this report goes to press, the United States Environmental Protection Agency (US EPA), which manages the TRI reporting program and database, is considering the expansion of the federal TRI to include materials accounting data. Public hearings have been held on the subject, but a decision has yet to be made. INFORM's research for this report makes it clear that this data, if collected throughout the nation on chemical producing and using facilities, would enable a new and valuable means for industry leaders, government agencies, and environmental groups to measure, and thus promote, pollution prevention progress. These data would also provide a critical component of the basic information necessary for tracking the movement of toxic chemicals throughout commerce and would help identify opportunities to avoid harmful exposures.

SUMMARY OF FINDINGS

INFORM's research in this report shows three unique ways in which the materials accounting data are useful:

• Materials accounting data provide preliminary information needed for assessing potential worker and community exposures because they identify which toxic chemicals are used at industrial facilities in New Jersey and in what quantities.
• Materials accounting data provide a means of measuring the results of source reduction activities by assessing the efficiency with which companies are using chemicals. An increase in efficiency suggests that source reduction activity is occurring.
• Materials accounting data provide a means for regulators to verify the accuracy of chemical quantities reported to the Toxics Release Inventory.

Using materials accounting data to conduct analyses, INFORM found:

• While New Jersey facilities used more toxic chemicals and generated more waste between 1991 and 1994, they appeared to use chemicals more efficiently in terms of reducing the percentage of total use that ended up as waste (waste output dropped from 3.6 percent to 3.5 percent of use).
• However, the data show that facilities were less efficient in other ways: for chemicals that were not intended to be part of the final product, a larger portion ended up in the product anyway.

This report also compares the picture of toxic or hazardous substances flowing through an industrial facility that can be seen using data available through a materials accounting system versus the picture seen using the more limited TRI information.

Toxic chemical use increased in New Jersey from 1991 to 1994, but the use of particularly hazardous chemicals dropped.

• The use of toxic chemicals in New Jersey increased by 633 million pounds, about 5 percent, to 13.3 billion pounds.
• In contrast, the use of chemical classes of special concern in New Jersey decreased as follows: bioaccumulators, 33 percent; carcinogens, 5 percent; chloroorganics, 14 percent; haloorganics, 16 percent; heavy metals, 18 percent; and ozone depleters, 64 percent.

Waste generation* in New Jersey increased from 1991 to 1994, but facilities reported the highest level of source reduction in 1993.

• The quantity of waste generated increased by 9.3 million pounds, about 2 percent, to 466 million pounds in 1994.
• In 1993, the latest year for which such data are available, New Jersey facilities reported reducing 4.4 percent of waste through source reduction, the highest percentage source reduction reported in New Jersey this decade. As of the 1994 reporting year, citizens of New Jersey are not able to quantitatively track source reduction progress because the NJDEP no longer collects data on the pounds of waste reduced through source reduction for those facilities that are required to prepare pollution prevention plans. Eventually, all reporting facilities will be required to prepare plans and will not be required to report the quantity reduced at the source.
• New Jersey facilities required to prepare pollution prevention plans project a greater percent decrease in waste generation than those not required to plan. On average, New Jersey facilities project a decrease in waste generation, while the rest of country's facilities project an increase in TRI waste generation.

The efficiency of chemical use by New Jersey facilities increased from 1991 to 1994 according to some measurements of efficiency and decreased according to others.

• A smaller portion of the total amount of chemicals used ended up as waste: waste as a ratio to use dropped from 3.6 percent to 3.5 percent.
• New Jersey facilities were more efficient in 1994 than in 1991 at incorporating toxic chemicals intended to be part of the product into products, thus avoiding their becoming part of the waste stream.
• New Jersey facilities were less efficient in 1994 than in 1991 at keeping chemicals (such as solvents, catalysts, and other processing aids) out of products when the chemical was not intended to be part of the product. That is, the ratio of the quantity shipped as (or in) product to use increased for this group of chemicals, with 1.63 billion pounds shipped in products. This raises the possibility of additional human or environmental exposures during product use or disposal.
• New Jersey facilities were also less efficient in 1994 at using chemicals that were not intended to be part of the product: the ratio of waste to use increased for this group, meaning more ended up in the waste stream per pound of chemical used. (A total of 178.5 million pounds of these chemicals were generated as waste in 1994.)
• The use of chemicals of special concern (i.e., bioaccumulators, carcinogens, chloroorganics, haloorganics, heavy metals, and ozone depleters) used only as reactants (chemically converted in production processes to form the product) increased in efficiency in 1994; that is, a larger portion of these chemicals used was converted to product and a smaller portion was generated as waste or shipped as a contaminant in the product.
• For chemicals of special concern (except heavy metals) that were intended to be incorporated into the product shipped from the facility, efficiency decreased in 1994; that is, less of the chemical was shipped as (or in) product per pound of chemical used, and more was generated as waste per pound used. (A total of 6.6 million pounds of these chemicals were generated as waste in 1994.)

Materials accounting data allow rankings of industry sectors according to efficiency of chemical use.

• Of the 20 industry sectors required to report materials accounting data in New Jersey in 1991 and 1994, the petroleum industry (SIC code 29) ranked first in inefficient use of chemicals not intended to be part of the product, shipping 1.6 billion pounds of such chemicals in product in 1994. At the same time, materials accounting data show that this industry appeared to achieve some progress in 1994, shipping a smaller percentage of such chemicals in product in 1994 than in 1991 (93.6 percent compared with 95.4 percent).
• Three out of 20 industry sectors showed improved efficiency at using chemicals that were intended to be part of the product: petroleum (SIC code 29), chemicals (SIC code 28), and primary metals (SIC code 33). All of these industries incorporated a greater portion of such chemicals into the final product in 1994 than in 1991 and kept a greater portion out of the waste stream.
• Five out of 20 industry sectors showed a decline in efficiency at using the chemicals that were intended to be part of the product: stone/clay/glass (SIC code 32), measurement/photography (SIC code 38), fabricated metals (SIC code 34), machinery (SIC code 35), and plastics (SIC code 30). These industries generated a greater portion of these chemicals as waste in 1994 compared with 1991 and incorporated a smaller portion into the final product.
• Three of four industry sectors in New Jersey showed improved efficiency at using materials as reactants; these are chemicals which by their nature react easily with other chemicals, including those in organisms and the environment. Measurement/photography (SIC code 28), chemicals (SIC code 28), and petroleum (SIC code 29) consumed (i.e., chemically converted) a greater portion of chemicals used as reactants in 1994 than in 1991. Plastics (SIC Code 30) remained steady during this time period.

Materials accounting data raise unique questions about industry's use of chemicals.

• A comparison between waste transfers (TRI data alone) and product imports/shipments (New Jersey materials accounting data) for all chemicals and all facilities in New Jersey reveals that chemicals transported as (or in) products shipped to (or from) facilities represent the lion's share of the chemicals transported in New Jersey, suggesting that the potential risks posed by the movement of chemicals in products deserves greater scrutiny.
• Which chemicals are identified as priorities for reduction in New Jersey depends on whether TRI or materials accounting figures are examined. For example, TRI figures show that the amount of carcinogens transferred as waste increased from 3.6 million pounds in 1991 to 6.5 million pounds in 1994, while materials accounting data show that imports of carcinogens as (or in) products to New Jersey facilities decreased by a few thousand pounds in 1994 and shipments of carcinogens as (or in) products reportedly fell from 635 million pounds in 1991 to 572 million in 1994.
• Materials accounting data can raise important questions about specific industrial facilities that would remain completely hidden by a TRI analysis. For example, because materials accounting includes use data, a comparison of two facilities using the same chemical (phthalic anhydride) for the same reported activity-use (as a reactant) to produce similar products (synthetic resins) revealed one facility to be more efficient than the other in terms of the portion of total use converted to product or generated as waste between 1991 and 1994. While materials accounting data do not provide answers as to why this difference would occur, without such data, the question (likely to be of interest to the community, NJDEP, and the facilities themselves) would not have been raised in the first place.
• Another example of questions uniquely raised through materials accounting data analysis is the identification of inaccurate or underreported releases or discrepancies in waste management figures. This was the case for ethylene oxide reported by the Johnson & Johnson Consumer Products facility in New Brunswick, New Jersey. The total materials accounting input and output quantities reported by the facility did not match, thus raising questions as to the fate of over 115,000 pounds of the chemical. TRI data alone would not have caught this reporting error.