12
Use versus Release
Reporting
INTRODUCTION
Although the Toxics Release Inventory (TRI) program has been successful in initially reducing the use of toxic chemicals, to continue to build on this success,
releases of toxic chemicals contained in the products sold to customers versus just
releases to environmental media, actual use of toxic chemicals by manufacturers
versus just releases, and worker exposure now need to be addressed. It is important
to note that it is expensive to track releases by each source in the factory. As part
of the TRI process, the company must determine use of the chemical to determine
if the releases of that chemical need to be quantified and reported; however, the
data determined on use itself are not reported. This chapter presents a comparison
between use and release reporting and programs aimed at reducing use. If we limit
use, we will reduce worker exposure to toxic chemicals and releases, both directly to
the air, water, and land and indirectly through products sold to customers.
COMPARISON OF USE AND RELEASES
Based on the toxicity units (TUs), in doses per capita, developed in Chapter 10 of this
book, chromium, cobalt, lead, and mercury were determined as among the chemicals
with the highest TUs. In Chapter 10, TUs were calculated by multiplying the effective toxicity factors (ETFs) in doses per capita-pound by the 2007 release amounts
reported in TRI (pounds) to determine the toxicity threshold of a chemical if the
2007 releases of a chemical were distributed evenly, and equal exposure occurred,
over the population of the United States. This section presents a comparison between
use and releases of some of these chemicals with higher TUs to demonstrate the
magnitude of difference between the level of use and releases of chemicals in the
United States. This further demonstrates the importance of reporting and subsequently targeting reduction of the use of relatively higher toxicity chemicals versus
just release reporting and targeting reduction of releases.
According to the U.S. Geographical Survey Mineral Commodity Summaries,
2007 apparent consumption of chromium in the United States was 629,000 metric
tons as compared to the U.S. TRI 2007 release data of 27,398 metric tons (5,338 metric
tons of chromium and 22,060 metric tons of chromium compounds). Since chromium
is not a material that is consumed or destroyed in processing, release reporting only
accounts for less than 5 percent of the use. The rest is either released by users who are
not required to report under TRI or is a component of products. Similarly, the 2007
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