IPC testifies before congress on EPA's toxic release inventory programme

Citation

(2004), "IPC testifies before congress on EPA's toxic release inventory programme", Circuit World, Vol. 30 No. 2. https://doi.org/10.1108/cw.2004.21730bab.002

IPC testifies before congress on EPA's toxic release inventory programme

IPC testifies before congress on EPA's toxic release inventory programme

Keywords: IPC, Environmental regulations, Waste management

IPC has testified before a US House of Representatives Committee on Resources, Subcommittee on Energy and Mineral Resources on the significant burden the Environmental Protection Agency's (EPA's) Toxic Release Inventory (TRI) program places on small businesses throughout the electronics interconnect industry.

The TRI program requires businesses to report toxic chemical releases and other waste management activities to EPA for public access. In April 2001, EPA released a revised rule that lowered the TRI reporting threshold for lead and lead compounds from 25,000 to 100lb, after applying persistent, bio-accumulative and toxic criteria that were developed for the evaluation of synthetic organic compounds.

At the hearing, small business supporters and representatives from both the metal and mining industries joined IPC in reiterating the inaccuracy of EPA's basis for the TRI rule. The groups backed recent findings from the EPA-appointed Science Advisory Board, which concluded that the principal theoretical features of the model used by EPA in evaluating the bioaccumulative nature of an organic chemical should not have been used to assess lead and lead compounds because they are inapplicable to lead and other inorganic metal substances.

The testimony of Fern Abrams, IPC's Director of Environmental Policy, outlined EPA's significant underestimate of the substantial burden that the TRI rule places on small businesses. She rebuked EPA for not convening a Small Business Advocacy Review Panel, for failing to reach out to small entities during the development of the rule and for not completing its promises to assist small business through the establishment of workshops and a TRI Lead Rule Hotline.

"Compliance with the lowered reporting thresholds has imposed a large and significant burden on affected businesses, including IPC members," Abrams testified. "For a small business, the job of interpreting and complying with the agency's instructions and guidance for the TRI is a substantial source of burden. The reporting forms, instructions, and guidance for complying with the reporting requirements for lead and lead compounds together total 746 pages, not including 12 industry specific guides, which, after 2 years, still have not been updated to include the lowered reporting thresholds."

On behalf of IPC members, Abrams requested EPA to undertake serious efforts to streamline TRI reporting and refocus the program on significant environmental releases.

For more information, contact: Abrams at FAbrams@ipc.org or 202-962-0460.