In the October 1, 1996 Federal Register (pp 51321-51330), EPA has 
proposed expanding its Community-Right-to-Know Initiatives
to require information on chemical use.  It is proposing to use
the SARA 313 TRI process to gather this data, and make it publicly
available.  Comments are due on or before December 30, 1996.

This process has been ongoing for quite a while, and has been known
as the TRI-Phase 3 Project. To quote from the notice "...EPA believes
that material accounting has the potential to significantly increase
the utility and completeness of data that would be available to
identify, evaluate, and track toxic chemicals in the workplace and
community."  EPA seeks to require that companies submit data that
shows the amounts of the TRI chemicals that they use, not just what
is released or is transferred off-site.  This information could
possibly come from purchasing records combined with MSDS information.
Two states already require this type of information (New Jersey and
Massachusetts).

In addition, EPA is considering requiring data on chemical outputs,
such as amounts of TRI chemicals produced, transformed into other
chemicals, or present in products leaving the facility.  And if that
isn't enough, EPA is considering requiring data on occupational
exposure, such as how many employees are exposed to this chemical, 
or asking whether employee exposure assessments were performed during
the year, or ever.

Some of the stakeholders in the EPA meetings on this issue have
suggested using this data to create a "scorecard" for measuring
and promoting pollution prevention/source reduction, or as a ledger
check on TRI estimates, or for other uses such as research and
priority-setting.

EPA is requesting comments on ~35 specific questions regarding this
proposal. If you would like a copy of the notice, please e-mail me
and I will forward it to you (or I can fax a copy).  I hesitate to
send this out to ComplianceNet since it is 30 pages long.  I do 
think that we should discuss this notice at the EHSWorks in Naples, 
and develop an industry response.

Please contact me for copies of this notice or more info.



John Sharp
Merix Corp.
Forest Grove, OR
503-359-9300 (ext. 5-4351)
503-359-1040 FAX
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