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Re: Targeting top TRI reporters for reductions



Cindy McComas:

When I was working for the EPA, we used a similar idea to target
facilities for audits.  It is a good idea and can yield good results. 
Theoretically, you can make the most difference at a facility that is
releasing a lot of chemicals.

However, we had one major problem with the concept. The companies
reporting large quantities of releases are often better at quantifying
releases.  The large companies have environmental staffs that can
adequately estimate their releases.  The large environmental staff also
allows the large companies to deal with their emissions.

We found the smaller companies without large environmental staffs, and
the companies that do not report releases had more problems and we were
able to make more of a difference with them.  However, our time spent at
the companies reporting high quantities of releases was not wasted.  We
learned a great deal from these companies and we were able to share
these ideas with other companies.

Another problem with the theory is, for many large companies, the
emissions are coming from numerous processes across their facility.  We
were unable to go into their facility and find one big problem that was
causing the large quantity of releases.  If a facility did not have an
environmental commitment from management, then we were able to make a
diffence.  Other than management commitment, auditing a large company
with a large amount of releases was no more productive than auditing a
small company with a small amount of releases.

I hope this helps,

Brian Wanzenried