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A Program to Reduce Toxic Chemical Use
minimal fees. Toxic chemical use fees would be levied for use of the toxic form
of the compound. For chromium, this would be hexavalent chromium. For cobalt,
it would be for its use as a fine grain or use that would generate a fume.
INCENTIVES
Changing a process to reduce or eliminate use of a toxic chemical can be expensive.
For instance, converting a typical 275,000-ton/yr chloralkali plant, a producer of
chlorine and sodium hydroxide, from mercury cells to the newer membrane cells
that do not use mercury cost approximately $112 million in 2006 dollars. These
conversions are needed but are hard to justify when competing for other projects that
could expand the market for a company. By using toxic chemical use fees to provide
low-interest loans, the fees can be leveraged, along with the prospects of reducing
the fees to provide incentive for companies to invest in changes. Grants associated
with fee revenue to cover a portion of conversion costs would also leverage the fees.
Another way to leverage the fees and provide an incentive for change would be
to reward companies that demonstrated a reduction in the total effective toxicity
associated with their toxic chemical use from year to year. One possible method
would be to establish a credit to be earned based on a factor multiplied by the
effective toxicity reduction percentage. For example, if the factor was set at 2, then
a company that reduced its effective toxicity by 50 percent from the previous year
would earn a 100 percent credit multiplied by the fees that would be imposed for the
year or, in this example, end up not paying fees for that year. This type of system,
which would be reset each year, rewards reductions in toxic chemical use each year
based on the ability to reduce the effective toxicity compared to the previous year,
encouraging an ongoing reduction in subsequent years.
CHEMICAL USE REDUCTION PLANNING
Many companies are not aware of the opportunities they have to reduce use of
toxic chemicals. As noted in this book, in the case of the current TRI program,
the established program chemical use thresholds require “behind-the-scene”
quantifications of chemical uses to determine if reporting requirements on
releases of the chemical to the environment are triggered. In our proposed toxic
chemical use reduction program, the same TRI program chemical use thresholds
would remain; however, they would be used to determine when chemical use
reduction planning requirements are triggered. Requiring that companies using
toxic chemicals above use thresholds (the same use thresholds that the current
TRI program requires) evaluate alternatives to reduce use and perform a costbenefit analysis would make the existing costs and benefits of conversion available to managers.
In one case example, one of us was performing a pollution prevention analysis of
the missile division of Martin Marietta. The plant was required to clean the missile
surface with a virgin cloth and TCE. Barrels of solvent-contaminated cloth were disposed by incineration, costing thousands of dollars per week. When this was pointed
out to the plant manager, he found that most of the rags were being produced by staff