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RE: TRI reduction



I want to start by acknowledging that I agree with the concept of emission
reductions. As a member of the chemical manufacturing industry I must
caution against mandatory reductions. The chemical industry (CMA) has made
greater than 50% reductions in TRI emissions over the last 10 years. Many of
us participated in the voluntary EPA 33/50 Program. Since we have been
making reductions since the late 1980's, further reductions have become more
difficult and/or technically infeasible. Unlike industries that only USE
chemicals, the chemical manufacturing industry must also process and or
react chemicals to make our products. Some of the raw materials are
chemically essential to the end product and cannot be substituted. Many of
these are TRI chemicals. The public and regulatory agencies must keep in
mind that many of these chemicals are responsible for our current standard
of living and quality of life. Making mandatory reductions may result in the
loss of businesses and products that have benefits to society that may be
greater than the harm due to emissions. (Just think of the chemicals used to
make the computer you are currently using.)

Increasing regulations usually puts an additional paperwork burden on
companies and may also direct resources towards reducing "reportable"
chemicals instead allowing companies to conduct a Risk Assessment to
determine which chemicals would be better to target for reductions.
Voluntary initiatives, partnering with companies and working with Trade
Organizations have shown to be an effective mechanism to understand and
target pollution prevention strategies.

Joann Cortese, CHMM       
*: (610) 344-2133
Fax:(610)692-8632
cortese@sartomer.com