4
Toxic Chemicals
Although the TRI has been successful in initially reducing the use of toxic chemicals, to continue and to build on this success, release of toxic chemicals contained
in the products sold to customers (vs. just release to environmental media), actual
use of toxic chemicals by manufacturers (vs. just release), and worker exposure now
need to be addressed. It is important to note that it is expensive to track release by
each source in the factory. As part of the TRI process, the company must determine use of the chemical to determine if the release of that chemical needs to be
quantified and reported; however, the data determined on use itself are not reported.
Chapter 12 presents a comparison between use and release reporting and programs
aimed at reducing use. If we limit or eliminate use, this would contribute to reduced
worker exposure and release, both directly to the air, water, and land and indirectly
through products.
One method of reducing use or release of toxic chemicals is through requirements
that companies prepare pollution prevention plans and set goals for reducing use or
release. Such existing programs are reviewed in Chapter 13.
Providing technical assistance is an important component of pollution prevention
programs. They provide assistance to small businesses as they search for information on alternative chemicals to use and proven process changes needed to eliminate
the use of toxic chemicals. These technical assistance programs provide a central
repository of industry-specific best management practices that can help diverse
and otherwise competing companies. Existing technical assistance programs are
reviewed in Chapter 14.
In recent years, alternative market-based approaches (vs. the traditional “commandand-control” strategy) for achieving environmental protection have evolved. Chapter 15
reviews these approaches and how they might apply to a program aimed at reducing
or eliminating the use of toxic chemicals.
In Chapter 16, we lay out a proposed program for reducing the use of toxic
chemicals. This program is an initial proposal that builds on the existing TRI program and uses lessons learned from this program, similar programs overseas, and
other U.S. state-based toxic chemical use reduction programs aimed at minimizing
the impacts of toxic chemicals. The impetus and intention behind proposing the
program in this book is to spur thinking among other professionals, particularly
federal-level policy makers, about the “next level” of toxic chemical use reduction
with the ultimate goal of instituting policy updates that build on and continue the
success of the TRI and other associated programs. Regardless of how successful past
programs have been, to continue progress in any field (especially those in which public health is concerned), it is the responsibility of professionals like us to reflect on
what has worked and what needs to be changed based on the world as it has evolved.
Our proposal is certainly not set in stone; in fact, we welcome healthy discussion
and suggestions regarding our proposed program elements and what modifications,
if any, would maximize the effectiveness of the next-level U.S.-based toxic chemical
use reduction program. Because this is an initial proposal to generate a new way of
thinking and move toward certain toxic chemical use reduction policy adjustments,
we also recognize that if select or even all proposed program elements proposed in
this book are deemed appropriate, additional refinement of details will be required
as part of actual program implementation to convert these ideas into actual policy.