Not so, says the Chemical Manufacturers Association. The EPA's TRI list includes six of the eight basic chemicals derived from petroleum. Companies would have to report the amount of chemicals used in thousands of products made from petrochemicals, many of which have no known substitutes.
The TRI list of 650 chemicals also includes 20 percent of the earth's basic elements. Aluminum, antimony, bromine, chlorine, cobalt, chromium, copper, fluorine, lead, zinc, phosphorous, manganese--these and other basic elements are listed as toxic chemicals. There are no substitutes for basic elements.
One half of the top 100 chemicals produced and used in the United States are on the EPA's list of toxic chemicals. Many of the remaining chemicals, while not on the list itself, require inputs of EPA-listed chemicals in their formulation.
All these chemicals provide building blocks for over 70,000 different end products, many of which are nontoxic despite requiring some toxic chemicals in their manufacture. These products include many household comforts, basic infrastructure, and health care essentials.
Aluminum, for instance, is used in aircraft wings. Chlorine is used in computer chips, asbestos replacements, vitamin B-6, X-ray films, acetaminophen, saline solutions, packaging, and the treatment of drinking water. Benzene is used to make backpacks, tents, photocopier toner, bleached paper, niacin, and computer disks. Name a modern product and behind it will often lie a TRI-listed chemical.
If reductions in the use of these chemicals could improve human health and reduce environmental risk, the EPA's policy might make sense. But the link between use of these chemicals and environmental risk is virtually nonexistent.
As toxicologist George Gray of the Harvard Center for Risk Analysis told Congress, "Chemical use does not equal chemical risk....Simply knowing how many pounds are used provides no information regarding health and environmental risks." That's no information. None at all. Zero.
The initial TRI reports at least listed actual releases of chemicals into air, water, or soil where there was some potential for exposure. Yet even the original list of 336 chemicals did not result from any methodical risk assessment. Instead, these chemicals were taken from other lists of chemicals developed by legislators in two states, New Jersey and Maryland. And those lists derived mainly from surveys of companies in those two states that identified, primarily, the chemicals with the largest production volumes.
A risk-based reporting system would focus either on chemicals that pose very high risks or on those to which the public is likely to be exposed at potentially dangerous levels. TRI, introduced under the premise that people have a "right to know" the scope of chemical risks, misleads the public about these risks and exposures.
People should be informed about potential risks involuntarily imposed upon them. The "right to know," applied in this sense, simply reinforces historic common-law notions of justice. But expanding TRI to include materials accounting moves environmental policy into an entirely different arena in which "sustainability"--the current mantra--is equated with reduced consumption rather than lower environmental impact per unit of output. Risk becomes irrelevant.
As the EPA has noted, what gets reported may, indeed, get reduced. The more important question is whether that reduction generates any meaningful public benefit. With materials-accounting reporting, the likely answer is no.
Editor's Note: We invite comments and request that they be civil and on-topic. We do not moderate or assume any responsibility for comments, which are owned by the readers who post them. Comments do not represent the views of Reason.com or Reason Foundation. We reserve the right to delete any comment for any reason at any time.
nfl jerseys|11.15.10 @ 10:18PM|#
nzxethtg
قبلة الوداع|8.16.11 @ 8:38PM|#
thank u