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A Program to Reduce Toxic Chemical Use
monitoring of their toxic chemical use by manufacturers and inform the
public of the presence, concentration, and characteristics of these chemicals
in the products they use.
3. Chemical Toxicity Rating: An ongoing effort should be made to determine the toxicity, mobility, persistence, and bioconcentration factors of the
toxic chemicals that are used and to refine factors to assign to these chemicals. One effect of assigning toxicity values to chemicals is to have users
switch to other chemicals, many of which do not currently have associated
toxicity data. In addition, we need to move away from the practice of inventorying under a single category name the different forms of a chemical that
have widely varying toxicities.
4. Chemical Use Reporting: Companies should monitor and report use or
production of toxic chemicals in addition to reporting on releases to the
environment. The companies that are currently required to report releases
already must measure use to determine if they need to continue measuring and reporting releases. Use reporting is much easier to implement than
release reporting and accounts for worker exposure, release in products
(to end users), and release to the environment. Chemical use reporting
should be expanded beyond the companies presently in the TRI program.
5. Public Disclosure: To incentivize toxic chemical use reduction, publish
successes (positive public publicity) and chemical use inventory disclosure
(via the Internet).
6. Toxic Chemical Use Fee: Base a fee on toxic chemical use multiplied by an
effective toxicity factor (ETF) to place the toxic impact costs for the use of the
chemical at the point where the chemical is used. This will provide an economic incentive for reduction while allowing its use for high-value uses. The
fee would be proportionate to the level of toxicity adjusted by factors to account
for the mobility, persistence, and tendency to bioconcentrate of the chemical.
7. Incentives: Any money collected as toxic chemical use fees would be used
to fund research and development of alternative chemicals and processes
and provide incentives to chemical users to pay for changing processes.
Incentives could be in the form of low-interest loans or grants to companies
to change manufacturing processes. Money could also be used to pay for
the health impacts caused by the current use of toxic chemicals.
8. Chemical Use Reduction Planning: Companies that use toxic chemicals
should be required to evaluate process changes or product reformulations
that would reduce or eliminate use of toxic chemicals. Planning would consist of inventorying use of chemicals, evaluating alternative processes and
materials, funding cost-effective projects, and setting toxic chemical use
reduction goals.
9. Technical Assistance: It is in the public interest to reduce use of toxic chemicals. By having a central organization to provide information and technical
assistance to implement cost-effective technologies for reducing or replacing
toxic chemicals, toxic chemical use reduction can be accomplished faster and
more efficiently than if individual companies were required to do it on their
A Program to Reduce Toxic Chemical Use
monitoring of their toxic chemical use by manufacturers and inform the
public of the presence, concentration, and characteristics of these chemicals
in the products they use.
3. Chemical Toxicity Rating: An ongoing effort should be made to determine the toxicity, mobility, persistence, and bioconcentration factors of the
toxic chemicals that are used and to refine factors to assign to these chemicals. One effect of assigning toxicity values to chemicals is to have users
switch to other chemicals, many of which do not currently have associated
toxicity data. In addition, we need to move away from the practice of inventorying under a single category name the different forms of a chemical that
have widely varying toxicities.
4. Chemical Use Reporting: Companies should monitor and report use or
production of toxic chemicals in addition to reporting on releases to the
environment. The companies that are currently required to report releases
already must measure use to determine if they need to continue measuring and reporting releases. Use reporting is much easier to implement than
release reporting and accounts for worker exposure, release in products
(to end users), and release to the environment. Chemical use reporting
should be expanded beyond the companies presently in the TRI program.
5. Public Disclosure: To incentivize toxic chemical use reduction, publish
successes (positive public publicity) and chemical use inventory disclosure
(via the Internet).
6. Toxic Chemical Use Fee: Base a fee on toxic chemical use multiplied by an
effective toxicity factor (ETF) to place the toxic impact costs for the use of the
chemical at the point where the chemical is used. This will provide an economic incentive for reduction while allowing its use for high-value uses. The
fee would be proportionate to the level of toxicity adjusted by factors to account
for the mobility, persistence, and tendency to bioconcentrate of the chemical.
7. Incentives: Any money collected as toxic chemical use fees would be used
to fund research and development of alternative chemicals and processes
and provide incentives to chemical users to pay for changing processes.
Incentives could be in the form of low-interest loans or grants to companies
to change manufacturing processes. Money could also be used to pay for
the health impacts caused by the current use of toxic chemicals.
8. Chemical Use Reduction Planning: Companies that use toxic chemicals
should be required to evaluate process changes or product reformulations
that would reduce or eliminate use of toxic chemicals. Planning would consist of inventorying use of chemicals, evaluating alternative processes and
materials, funding cost-effective projects, and setting toxic chemical use
reduction goals.
9. Technical Assistance: It is in the public interest to reduce use of toxic chemicals. By having a central organization to provide information and technical
assistance to implement cost-effective technologies for reducing or replacing
toxic chemicals, toxic chemical use reduction can be accomplished faster and
more efficiently than if individual companies were required to do it on their