The Environmental Protection Agency (EPA) continues to review the hundreds of comments it received on burden reduction proposals for the Toxic Release Inventory (TRI) program. EPA outlined the proposed changes in a 2003 white paper in Phase II of the TRI Stakeholder Dialogue.

EPA received over 650 comments from individuals, corporations, public interest groups and government agencies. It appears that various public interest groups were able to mobilize a significant number of individuals to submit comments on the TRI proposals. Public interest groups and citizens consistently raised concerns that the proposals would significantly weaken the TRI program. Not surprisingly, the industry comments appear to be supportive of all the burden reduction options put forth in the white paper with no concern for the integrity of the TRI program. OMB Watch, in its comments to EPA, strongly opposed the options proposed in EPA’s White Paper. To look through all the comments EPA received click here and search for TRI-2003-0001.

The only burden reduction options that reportedly received fairly broad support is the option to allow facilities to simply report “no significant change” rather than calculating and reporting detailed figures on their toxic waste. The general reaction was that if properly defined, this option could reduce reporting burden for certain facilities without a serious loss of information.

OMB Watch disagrees with this assessment. A facility must complete all of the standard reporting calculations to determine if it could use this option. Therefore, the facility would only avoid a small amount of paper work. Additionally, if the option is implemented with a broad definition of “no significant change” to ease use, it would likely diminish the accuracy of the ranges reported and consequently the accuracy of the TRI program. To read OMB Watch’s comments on the burden reduction options click here.

It is unclear how long it will take EPA to fully review all of the comments received or which, if any, of the burden reduction options it will develop further. OMB Watch will continue monitor EPA’s activities on TRI.