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Re: TRI data

In Colorado we have used the Indiana calculation of P2 Progress. It seemed to give a "big picture view" of actual releases versus those if no "pollution prevention" (using a broad definition) had occured.

However, a susequent study by Tom Natan of the National Environmental Trust ( tnatan@environet.org ) presented at NPPR last March indicates the TRI Production Index is not an accurate predictor of changes in production-related waste/releases. I believe he compared TRI data with New Jersey material accounting data and found no correlation. 

In using the Production Index, we found numerous problems that can really have a big impact in a relatively less industrialized state like Colorado. New products, change in process, add-on pollution control, etc. at one of our larger facilities can impact releases greatly. These changes may not be well reflected in the Production Index or may be dominated by other products, processes, etc. 

Additionally, there is very little guidance on how this Production Index is calculated adding further uncertainty to any use of the data.

In Colorado, we use TRI data for prioritizing P2 efforts and have used the Hazardous Waste PBT list (USEPA) and the chemical comparison tool developed by the Indiana Clean Manufacturing Technology and Safe Materials Institute to generate a P2 Priority List for companies participating in our voluntary Governor's P2 Challenge.

Please contact me if you have further questions,

Kirk Mills
Pollution Prevention Program
Colorado Department of Public Health 
     and Environment
4300 Cherry Creek Drive So.
Denver, Co  80246-1530
Ph: (303) 692-2977
Fax: (303) 782-4969
Email: kirk.mills@state.co.us