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 [log in to unmask] ************************************************************************** * The mail list is provided as a service by IPC using SmartList v3.05 * ************************************************************************** * To unsubscribe from this list at any time, send a message to: * * [log in to unmask] with <subject: unsubscribe> and no text. * **************************************************************************