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EPA issued an Advance Notice of Proposed Rulemaking related to potential reassessment of PCB use authorization under the Toxic Substance Control Act. Public comments are due on July 6; EPA will also be holding public meetings. Learn more here…

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On April 6, 2010, EPA took another important step toward providing communities with additional information about toxic chemicals being released to the environment.

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The Agency is announcing that it is considering lifting the 1994 Administrative Stay of the Toxics Release Inventory (TRI) reporting requirements for hydrogen sulfide. EPA is now presenting its rationale for why the Stay should be lifted, based on an updated evaluation that includes new information on human health and environmental effects of hydrogen sulfide. Learn more here...

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ECOS is interested in how you would improve the Chemical Right to Know Program….

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Chemical right 2 know website

Submitted by Kirk Mills on Tue, 04/14/2009 - 12:34.

So far site is not very user friendly. Tried to look at/download a couple of talks, Michael Ash's and my own and either timed out (Firefox) or got an error in Internet Explorer: Security Error Loading Document info: 'Error #2048'.

Kirk Mills

Colorado SARA Program

Suggestions for improving site

Submitted by Mark Greenwood on Fri, 04/10/2009 - 17:18.

 

On behalf of the Coalition for Effective Environmental Information (CEEI), we appreciated the opportunity to review a prototype of the ChemicalRight2Know.org Website. CEEI is a group of companies and business organizations interested in improving policies affecting how environmental information is collected, used, managed and disseminated to the public.
 
We offer the following suggestions for further refinement of the Website:
 
1. As we understand it, ECOS and EPA do not intend to adopt or endorse the content of the reports, databases and analyses offered on this site. That statement needs to be articulated clearly and prominently upfront on the Home Page of ChemicalRight2Know.org site. Such a statement should not be buried on a back page of the site. Otherwise the distinction between this site and the official Websites of EPA and state governments will not be clear.
 
2. In browsing the site, the user is presented with a variety of reports, analyses, articles and blogs that discuss various applications of TRI data. A reader can find these documents under a variety of headings:
 
·        Research & Analysis
·        TRI Data in Action
·        News
·        Other Resources
It is difficult to tell what principles ECOS/EPA uses to place a given document in one of these categories. For example, the "Research & Analysis" documents, which carry a label that makes them appear more authoritative, do not appear different in nature from documents found in the other categories.   It would help to clarify what distinguishes these different categories of documents or remove the distinctions and place all of the documents in a common category.
 
3. ECOS/EPA should be particularly careful in selecting what documents should be included in the "News" category. These documents, which are featured on the Home Page, are likely to get the most user traffic because of their location on the site and the natural tendency of people to want the latest information. 
 
We noted several examples where ECOS/EPA presented the personal blog of an individual as "News". Such blog sites included miscellaneous information about an individual along with an expression of opinion by the individual, based on TRI information (e.g., Kristee's Blog.) While we don't necessarily question the sincerity or analytical basis for the person's opinion, we think it is a mistake for ECOS/EPA to label the opinions of an individual blogger as "News". Such sites should be included, at the initiative of the individual, in the "Provide Feedback" part of the site along with other personal blogs. The News section should be limited to truly "new" information about TRI-related data and analysis backed up by institutions (government agencies, research institutions, journalistic organizations including "new media" Internet outlets) that operate with some accountability for accuracy and objectivity.
 
4. This site provides a great opportunity to provide a comment section following each of the documents posted so that others could provide supplemental information that would help clarify facts and issues surrounding a particular report. We assume ECOS/EPA would want to do this, but we could not tell from the prototype site whether this functionality will be provided for each report posted. We urge ECOS/EPA to provide such an online comment opportunity for each posted document.
 
5. The purpose of the "Learn More" section of the Website was unclear. It states the overall purpose of the site and then provides a link to information about ECOS. If the intent of this section is to provide background about the sponsors of the site, it might make sense to use an "About Us" or similar label for this section of the site.
 
6. CEEI appreciates that ECOS/EPA has developed a "Comment Policy" for the site that sets forth ground rules on civil discourse. It also is reasonable to ask commenters to register. We would suggest that ECOS/EPA expand this discussion into a general explanation about "governance" of the Website. A series of questions should be addressed in this section:
 
·        Who is managing this site? What is the role of ECOS and EPA in its financing and management?
·        What criteria will the site managers use for selecting content for the site? This would be a place to clarify what types of information will be considered as "News" and what kinds of documents will be posted under other categories in the site. This section could also address how site managers search for content. While this site is still under development, it has included only a fraction of the many recent reports and articles that include TRI information. We have not seen, for example, reports from the business community that utilize TRI data. Understanding how content is being selected would clarify how representative the site is.
·        When does the site post original content (e.g., a newspaper article) and when does the site post the commentary of another group that incorporates original content documents? How does the site address copyright issues?
7. It was not always clear that the site will be limited to applications of TRI data. For example, one of the reports cited in the News section, addressed climate change. In addition, the Mashup page indicates that a "mashup" is a "Web application that allows sharing detailed information about a key environmental issue so people can make informed decisions." This could be interpreted as an open-ended invitation to submit information on a variety of environmental issues that do not involve TRI data. The scope of the site should be clarified.
 
8. As a final comment not directly related to the design of ChemicalRight2Know.org, we were concerned about the design of the MapEcos site that was featured in the Mash Ups section of the Website.   It portrays itself as "a collaborative website designed to provide an evenhanded view of industrial environmental performance." This Website, however, provides profiles of individual facilities that are difficult to interpret due to a lack of explanation about the methodologies, definitions and non-TRI sources of information used in the site. It is an example of a site that would benefit from greater transparency and a better public explanation of how it drew conclusions about environmental performance.  

possible areas to expand, and improve TRI, & a CDX comment too.

Submitted by walterhope on Tue, 04/07/2009 - 12:46.

*comments are of the writers, and not sanctioned by his employer.

** Writer is a past TRI state Contact, also past FOSTA-TRI Member, and past NPPR Board Member

changes, expansion, improvements:

- revisit TRI expansion (phase IV?) which was looking at materials balance, including adding the chemical USE numbers.  We've had this data in MA since 1989.  for a company to accurately report their emissions, they MUST know how much they used in the first place, it adds value, adds information that can be used for better risk analysis (transport of materials to the facilities has risk (spills, accidents on highways, rail, shipping), and can be cross referenced with TIER II data as well

- add chemicals, a MA draft law has text that say's something like 'commerce has added 80,000 chemicals to production, while MA tracks some 1400'... while TRI tracks some 700 chemicals, this highlights the tremendous lack of information that exists.  If the TRI is truly for the "Community Right to Know", how can the "community" possibly know what the chemicals and risks are if over 75,000 chemicals used are NOT being tracked?

- add nano materials as a 'category'.  While the quantity manufactured and used may be well below the current 'high' thresholds, use the PBT case to expand to gather nano material information.  Explore the legal situation to see if the FTE count in this unique instance can be lowered as well.  Apply the precautionary principle to make this 'happen' (little is known, compounds are in commerce, and there is little to nothing known about the short term impacts/risks, and less known about the long-term impacts/risks.  if a nano material is used in a consumer product, what happens to it 1-100 years after it's intended use, and then what happens when it is 'thrown away (recycled, burned, land filled) ?

- add additional SIC/NAICS codes.  Again, MA has added additional codes and we have gathered additional information from facilities such as commercial laundries, waste-to-energy plants.  Add feed lots (corporate farming), the environmental impact of these facilities is often much greater than any 'factory'.

- remove some chemical exclusion (i.e.: ammonia is currently reportable only if it is fuming.  Is it not dangerous if it is liquid? )

- remove some USE exclusions (i.e.: the exclusion that allows beef (meat?) processing facilities to be exempt from reporting the levels of DIOXIN that are in the meat that they are processing)?

- add GHG chemicals to the mix

- make use on the forms the FRS ID#, if implemented this could greatly add to the transparency (to use a popular term) of corporate responsibility.

- Or, use FIEN# (with FRS ID#?)

- merge Tier II reporting (storage on-site) with TRI

- 'mine' the various databases @ EPA and other sources to find potential inconsistencies and non-filers

Finally, stop supporting 2 systems for transmitting TRI data to the states (EPA web site & CDX).  Since CDX data retrieval is expensive & complex, and 'only' 22 (?) states are forecast to use it, leaving the rest of the states without access, build the EPA web site for TRI to a point where a state (or anyone) can download the data (all), allow them the same (or better) 'front end' interface so that they can build reports, make comparisons and massage the data any way needed - and download/import the result.

 

Networking Researchers

Submitted by stephan on Wed, 04/01/2009 - 15:03.

It would be great if EPA could use the website to help network researchers.  Many of us are in contact, but not all.  A central location hosted by EPA might help.

Also, keep inviting researchers to this training event -- we have things to learn and things to teach too.

TOXMAP is not really a mash-up

Submitted by toxmap on Tue, 03/31/2009 - 15:41.

Just FYI.  Maybe put it in the "Other Resources" category?

domain name

Submitted by toxmap on Tue, 03/31/2009 - 15:39.

Make sure to reserve similar domain names like chemicalrighttoknow in .org, .com, and .net flavors.

Be Bold

Submitted by smoulton on Tue, 03/31/2009 - 14:46.

Moving beyond just collecting and distributing the data, EPA needs to begin selecting goals for improvement.  These should bold, difficult goals that are worth pusuing even thought they will be challenging.  The enourmous benefits that await us at the achievement will be a strong motivating factor to spur involvement by all stakeholders. 

 

The process of setting goals should be done as collaboratively as possible involving states, community groups, environmentalists, industry and others.  Honest discussion of drivers and barriers is an important component to ensuring that while the goals we set may be bold they are still achievable.