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Response to new CMA Report




The following is the response of the National Environmental Trust to the new
CMA report on the NJ and Massachusetts Materials Accounting Experience.  This 
report has already fomented a lot of (polite) discussion on the subject.  As
always any further comments or alternative points of view are welcome on 
either of these list serves. 


December, 1997


CMA Mischaracterizes Materials Accounting and Pollution Prevention

In its report "New Jersey and Massachusetts:  Toxic Use Reduction Successes? 
Models for National Programs?," the Chemical Manufacturers Association (CMA)
tries to prove that materials accounting data -- accounting for the flow and
use of chemicals into industrial facilities and out as products and waste --
not only is unnecessary and useless, but counterproductive as well, and should
not be added to the Toxics Release Inventory (TRI).  Furthermore, CMA attempts
to explain away real reductions in waste generation in Massachusetts and New
Jersey, the only U.S. states that collect materials accounting data.  But the
analysis is badly flawed.  The report abounds with factual errors (for
example, CMA insists that pollution prevention planning in New Jersey began in
1990 instead of 1993).  Inexplicably, CMA does not give credit to its New
Jersey facility members for the ambitious pollution prevention goals they
devised as part of the state's mandatory pollution prevention planning.  Here
are a few of the most important misstatements:

Myth:  Pollution prevention has not occurred in Massachusetts and New Jersey
because the amount of chemical use has risen in both states.

Reality:  According to the Pollution Prevention Act of 1990, pollution
prevention is measured by a drop in waste generation.  Waste generation in New
Jersey and Massachusetts has dropped since 1991, while waste generation for
the entire United States has gone up and is projected to rise even more. 
According to EPA's 1995 Toxics Release Inventory Public Data Release, waste
generation "has risen annually, for a net increase from 1991 to 1995 of nearly
seven percent... Facilities' projections for 1996 and 1997 show that they
expect very little change in how they handle their waste in the next two
years."

Myth:  The drop in waste generation in Massachusetts and New Jersey,
especially among New Jersey industries that were required to produce pollution
prevention plans, was mostly from large facilities with processes that were
shut down or from facilities that closed, and therefore wasn't a real
decrease.

Reality:  Obviously, large facilities that generate large quantities of waste
will dominate waste generation numbers.  However, even excluding those large
facilities from the New Jersey waste generation data, there was a net decrease
in waste generation among those industries required to submit prevention
plans.  Furthermore, the New Jersey planning law specifically forbids
facilities to include processes slated for shutdown in their plans, and
facilities still managed to set ambitious pollution prevention reduction
goals. In Massachusetts, the Toxic Use Reduction Institute recalculated its
waste generation figures using only those facilities that remained in business
throughout 1990-1995, and still shows a 16 percent reduction in waste
generation for those years.  Both states showed increases in efficiency, with
or without the facilities that closed.

Myth:  Since very few facilities in Massachusetts and New Jersey reported that
they identified source reduction opportunities through "State Programs," and
most reported that source reduction opportunities are generated internally,
materials accounting and pollution prevention planning cannot be responsible
for reductions in waste generation in those states.

Reality:  The goal of planning in Massachusetts and New Jersey is to make
facilities take a close look at their materials accounting data and generate
reduction opportunities internally.  As the above data indicate, the two
states' planning laws have succeeded in boosting this internal analysis beyond
that of other states.  Furthermore, an environmental consulting firm's evaluation
of New Jersey's planning process -- more in-depth than the EPA data on which
CMA bases its claim -- showed that 52 percent of facilities interviewed had
identified some or all of their prevention reduction activities through New
Jersey pollution prevention plans, and that materials accounting was key to
increasing reduction goals (Hampshire Research Associates, Alexandria, VA, May
1996). 

Myth:  Materials accounting would expand the definition of "pollution" to
include production and use of TRI chemicals.

Reality:  Materials accounting does not redefine "pollution," but it does
promote voluntary reduction of the hazards associated with the transportation,
handling, storage, use, and disposal of toxic chemicals.  Much of this is
accomplished by increasing the efficiency of toxic chemical use.  By CMA's own
admission, "the relative role -- in volume terms -- of TRI chemicals in the
U.S. economy is very likely to decline.  Assessments [over the last three
decades] indicate a marked decline in the growth of demand for industrial
chemicals relative to growth in the nation's output."  In other words, while
the economy and the standard of living have grown, U.S. industry has increased
its efficiency in using toxic chemicals.  This is analogous to fitting onto a
microchip computing power that once required a whole room.  Promoting this
trend and ensuring that it reduces hazards to human health and the environment
is one of the primary goals of the Massachusetts and New Jersey pollution
prevention programs.

Myth:  Materials accounting data do not show pollution prevention progress.

Reality:  Materials accounting measures chemical use efficiency, or how much
of a given chemical used to make a product ends up as waste.  In both
Massachusetts and New Jersey, the two states that require materials
accounting, the data show that industrial facilities are becoming more
efficient in their use of toxic chemicals, with less of the toxic chemicals
being released to the environment, burned, treated, or recycled out of the
production process.  This is the very essence of pollution prevention.

Myth:  The historical declines of toxic chemical waste and use per unit of
product are driven by powerful economic and technological forces that
overwhelm the effect of state programs, such as those in Massachusetts and New
Jersey.

Reality: One of the important drivers leading to implementation of these new
technologies is materials accounting data reporting.   Materials accounting
and pollution prevention planning are management tools which enhance
industry's knowledge about materials use and its ability to manage materials
more efficiently.  New technologies come about through a need to produce
products more cheaply, including generating less waste.  Again, promoting this
trend and ensuring that it leads to reduced hazard to human health and the
environment is an important goal of the Massachusetts and New Jersey toxics
use reduction programs.


===========================================================

Tom Natan
Research Director
National Environmental Trust
1200 18th Street, NW, Suite 500
Washington, DC  20036

202/887-8800
202/887-8880 (fax)
tnatan@acpa.com