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Costs and Benefits
facility owners to voluntarily reduce the toxic emissions of the facilities and has
demonstrated that the mandatory risk assessment/notification component has been
a powerful tool in getting industry to produce results. It is important to note that
skilled and sophisticated risk assessors or modelers are required under this type of
program to conduct the risk analyses required.
The “Hot Spots” program is an example of how a law can be good for the environment and business. Some of the surveyed companies reported that the preparation
of their air toxic “Hot Spots” emission inventory alerted them to the actual cost of
waste in their processes and motivated them to look for ways of streamlining their
operations. In addition, the “Hot Spots” emission inventory, combined with concern
for worker safety and the possibility of future regulation, led companies to reduce
emissions by substituting fewer toxic materials in their processes or by establishing
more efficient operations. These emission reductions lower the health risk to workers
and the public while helping to improve company performance and relations with
the community.
Inherent in this program are two strong factors that motivated industry (as with
the Massachusetts Toxics Use Reduction Act [TURA] program): (1) The plans
allowed industry to analyze production processes that use toxic chemicals to see
that cost-effective improvements can be made, and (2) there was public disclosure of
the amounts of toxic chemicals used and the assessment of the risk of those chemicals on the residents and workers surrounding an industrial facility. Individually
or combined, both these factors have resulted in improvements in toxic reduction
technology, in productivity enhancement in industrial processes, and in encouraging
the development of new technologies.
An ARB survey found 21 companies that voluntarily reduced air toxic emissions
by almost 2 million pounds. This sample of the California air toxic sources suggests a larger, statewide trend and points to a significant benefit of the “Hot Spots”
regulation . The state ARB has not compiled the emissions reductions from the AB
2588 program but rather left it up to the various local air pollution agencies to report
progress. While it is difficult to document the precise emissions reductions of air
toxics due to the Air Toxics “Hot Spots” program in California, the counties that
reported actual emission reductions indicated overall air toxics reductions of 60 to
90 percent. Reductions of individual toxic air emissions varied up to 100 percent.
The ARB and the Metal Finishing Association of Southern California received a
South Coast Air Quality Management District 1992 Clean Air Award for their work
to advance P2 and the control of hexavalent chromium emissions. The two organizations cooperated in a demonstration project showing that simple process changes,
combined with control equipment used successfully in other industries, consistently
reduced hexavalent chromium emissions well below the required emission limit. The
findings from this project will reduce exposure of the public to hexavalent chromium,
thus preventing up to 2,600 potential cancer cases over the next 70 yrs.
BIBLIOGRAPHY
American Chemistry Council. 2006. ACC Applauds EPA TRI Burden Reduction Measure.
Arlington, VA.
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