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A Program to Reduce Toxic Chemical Use
It is not necessary that we restrict toxicity data to that generated in the United
States. Part of the European REACH program is to collect toxicity data from
throughout the world and evaluate and determine the most acceptable values for
toxicity to use in regulating toxic chemicals. The current U.S. toxicity data cover a
range of over 12 orders of magnitude. It is better to have toxicity data that may be
off an order of magnitude than to have no values at all and assume that a substance
is not toxic.
Another point to consider is that the existing TRI chemicals list combines the
different forms of chemicals that have widely varying toxicities. For instance, the
category chromium and chromium compounds consists of three forms of chromium:
hexavalent chromium, trivalent chromium, and metallic or elemental chromium.
Hexavalent chromium is a potent carcinogen and is made from trivalent chromiumbearing ores. With very rare exceptions, metallic or trivalent chromium does not
convert to hexavalent in the environment. Trivalent chromium is an essential nutrient
and has a much lower toxicity. Elemental chromium is nontoxic and is used in stainless steel and highly inert products. As another example, nickel and cobalt fumes
and gases are carcinogens, but the metal salts and nonaerosolized metallic cobalt
and nickel are much less toxic. It would make sense to provide use reporting, and
efforts to reduce use, on hexavalent chromium and gaseous or micronized nickel or
cadmium. Each of the other chemicals that are categorized as highly toxic should
be evaluated to ensure that the toxic forms, or forms that can be converted to toxic
forms, are the forms that are individually reported for use.
Lastly, with time, an additional ecological risk factor could be incorporated into
our relative chemical-specific toxicity factors to adjust for impacts on other species
or other associated environmental impacts.
CHEMICAL USE REPORTING
We have noted that the existing TRI program only requires reporting on releases of
the chemicals to the environment, and that this does not account for the exposure
of workers to chemicals or inclusion of the chemicals in products. Companies that
report on a chemical under the TRI program are required to calculate use to determine if they need to calculate releases for each of many potential emission points.
Use calculation is inherently much easier with suppliers providing composition
information on chemicals and purchasing agents typically keeping extensive information on amounts of chemicals purchased. Use is a simple matter of multiplying
composition data by the annual use of each product. Release calculations add to the
complexity of tracking each chemical to its point of use and calculating release using
emission factors for each chemical and use. Reporting on use would require little
additional effort and still provide a measure of all releases and worker exposure.
PUBLIC DISCLOSURE
Public reporting of the data from the TRI database has been effective in spurring reduction in the release of the reported chemicals. It notifies neighbors of the
releases and therefore puts local pressure to reduce the releases. Public disclosure
A Program to Reduce Toxic Chemical Use
It is not necessary that we restrict toxicity data to that generated in the United
States. Part of the European REACH program is to collect toxicity data from
throughout the world and evaluate and determine the most acceptable values for
toxicity to use in regulating toxic chemicals. The current U.S. toxicity data cover a
range of over 12 orders of magnitude. It is better to have toxicity data that may be
off an order of magnitude than to have no values at all and assume that a substance
is not toxic.
Another point to consider is that the existing TRI chemicals list combines the
different forms of chemicals that have widely varying toxicities. For instance, the
category chromium and chromium compounds consists of three forms of chromium:
hexavalent chromium, trivalent chromium, and metallic or elemental chromium.
Hexavalent chromium is a potent carcinogen and is made from trivalent chromiumbearing ores. With very rare exceptions, metallic or trivalent chromium does not
convert to hexavalent in the environment. Trivalent chromium is an essential nutrient
and has a much lower toxicity. Elemental chromium is nontoxic and is used in stainless steel and highly inert products. As another example, nickel and cobalt fumes
and gases are carcinogens, but the metal salts and nonaerosolized metallic cobalt
and nickel are much less toxic. It would make sense to provide use reporting, and
efforts to reduce use, on hexavalent chromium and gaseous or micronized nickel or
cadmium. Each of the other chemicals that are categorized as highly toxic should
be evaluated to ensure that the toxic forms, or forms that can be converted to toxic
forms, are the forms that are individually reported for use.
Lastly, with time, an additional ecological risk factor could be incorporated into
our relative chemical-specific toxicity factors to adjust for impacts on other species
or other associated environmental impacts.
CHEMICAL USE REPORTING
We have noted that the existing TRI program only requires reporting on releases of
the chemicals to the environment, and that this does not account for the exposure
of workers to chemicals or inclusion of the chemicals in products. Companies that
report on a chemical under the TRI program are required to calculate use to determine if they need to calculate releases for each of many potential emission points.
Use calculation is inherently much easier with suppliers providing composition
information on chemicals and purchasing agents typically keeping extensive information on amounts of chemicals purchased. Use is a simple matter of multiplying
composition data by the annual use of each product. Release calculations add to the
complexity of tracking each chemical to its point of use and calculating release using
emission factors for each chemical and use. Reporting on use would require little
additional effort and still provide a measure of all releases and worker exposure.
PUBLIC DISCLOSURE
Public reporting of the data from the TRI database has been effective in spurring reduction in the release of the reported chemicals. It notifies neighbors of the
releases and therefore puts local pressure to reduce the releases. Public disclosure