INTERNATIONAL
COUNCIL OF
CHEMICAL
ASSOCIATIONS
15 September 2000
ICCA COMMENTS ON
POLLUTANT RELEASE AND TRANSFER REGISTER (PRTR)
INTRODUCTION
The International Council of Chemical Associations (ICCA) is a council of leading trade
organizations and their member companies representing chemical manufacturers in
Japan, Australia and New Zealand, Europe, and North and South America. ICCA
represents approximately eighty percent of worldwide chemical production. ICCA’s
focus is on developing global chemical industry positions and evolving programs on
issues of international significance to the industry in areas such as health, safety, and the
environment; international transport safety; intellectual property; trade policy; and
industry efforts to eliminate chemical weapons and diversion of illegal drugs. ICCA also
promotes and co-ordinates Responsible Care® and other voluntary chemical industry
initiatives. The chemical associations in forty-five countries implement ICCA’s
Responsible Care® initiative.
Pollutant Release and Transfer Register (PRTR) programs provide information on
releases of substances to the environment and on offsite transfers of the substances for
final disposal. These emission inventory programs -- which can be either government or
industry initiatives -- collect a range of information on substances into one data source.
The information in the inventory database may include a variety of emissions, including
air releases, water discharges and transfers off-site for disposal. Typically the
information is collected on a regular basis to allow tracking progress over time.
The International Council of Chemical Associations (ICCA) supports emissions
reporting and believes these programs can provide valuable information that can
help document and stimulate reduction in emissions and communicate information
to key audiences. All ICCA members support the reporting provisions of Responsible
Care® and several members have worked closely with governments to develop national
emission reporting programs. These programs vary considerably and there are ways to
improve them – which will be presented in this paper - but the basic concept and guiding
principles of the programs are sound.
In this paper, ICCA will focus on the applications of PRTR, specifically to industrial sites
producing and handling chemicals.
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BENEFITS OF EMISSION REPORTING
The value of a well-designed emission-reporting program is that it provides useful
information that increases awareness about emissions. Industry gains knowledge needed
to document and stimulate emissions reduction. Governments gain awareness and
understanding about national, regional, and local emissions. The public gains awareness
about emissions in their communities.
The modalities for emission reporting vary from country to country. Some countries
have enacted legislation, such as with the U.S. TRI - the first PRTR - while in others,
industry has established voluntary programs. For example, the European chemical
federations voluntarily report data on air, water and waste emissions, using the
comprehensive and clearly defined set of Responsible Care® Performance Indicators
developed by the European Chemical Industry Council (CEFIC). In addition, the
European Commission has recently adopted a binding European Pollutant Emission
Register (EPER)1, which would report industrial emissions to air and water exceeding a
certain threshold.
In the case of Canada, Australia, Mexico and the UK, national multi-stakeholder
processes were initiated to address important emission register design questions through a
dialogue involving all concerned parties. In Canada this process also benefited from the
Canadian chemical industry first having developed in 1992 a voluntary emissions
reporting program that served as an important input for the subsequent government
regulation that took effect in 1993. In Sweden, the Czech Republic and Switzerland,
initial emission reporting work focused on working with a select number of companies to
implement a pilot reporting trial. The Japanese chemical industry voluntarily initiated
emission reporting on a selected number of companies and substances in 1992 and
increased the number of substances and companies over time. When a national law was
enacted in 1999 the results from the voluntary program were integrated into the new
national system. In Brazil, where no national PRTR legislation exists, companies have
reported emissions data to the national chemical industry association as part of their
commitment to Responsible Care®. The results are still inconclusive but have clearly
indicated that the process of reporting is important to stimulate actual improvements.
The ICCA itself has started a discussion on performance indicators for the Responsible
Care® Program worldwide, aimed at providing data on different aspects of health, safety
and environment in the chemical industry. Employee’s safety information has already
been collected and environmental data may follow in the near future. The data will be
used to demonstrate the industry commitment to the continuous improvement of its
environmental performance.
Each of the referenced approaches provides valuable lessons and ideas from which other
countries may benefit.
Benefits to Industry
1
Commission Decision on the implementation of a European pollutant emission register (EPER) according
to Article 15 of Council Directive 96/61/EC concerning integrated pollution prevention and control (IPPC),
17 July 2000.
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Emission reporting information is useful to industry to determine current releases and
design new processes or modifications to existing ones that will result in a reduction in
emissions. The information helps identify opportunities for emissions reductions and to
establish reduction goals. Emission reductions are often driven by factors other than
regulatory requirements, most prominently the chemical industry’s commitment to
Responsible Care®, which promotes a range of risk reduction and management practices,
including source reduction. In addition, reductions are often linked to material and energy
savings, due to higher process efficiencies, creating a positive economic result.
Reductions have occurred in countries that use different approaches for reporting
emissions. For example, in Germany the chemical industry has made significant
reductions: in SO2 air emissions by 60%, in phosphorus water discharges by 42%, and in
energy-related CO2 emissions by 29% (from 1990) since the beginning of the voluntary
Responsible Care® reporting in 1995. In the first seven years of operation under the U.S.
PRTR program, the Toxic Release Inventory (TRI), the chemical industry documented a
50% reduction in releases, even with an 18% increase in production. Similarly, in the
first eight years of operation of an emission reporting system the Canadian chemical
industry documented a 90% reduction in releases of NPRI (National Pollutant Release
Inventory) substances and 60% reduction of total releases, while production increased by
27%.
To maximize emission reduction potential and to make these programs more costeffective, emission reporting programs should focus on environmental releases of the
industrial site as a whole, not on in-plant processes or materials use. Releases are directly
related to pollution. Materials use, however, does not imply pollution and the collection
of such data only increases the administrative burden while adding little useful
information relating to actual pollution. In addition, materials use data can contain
sensitive business information.
Industry can use emission reporting information to communicate with key audiences
about substances in the environment and how process changes can result in reduction in
emissions. The public typically views established emission reporting programs as trusted
and valuable sources of information. Thus, by focusing on emission reporting
information, industry and key publics can have fruitful discussions and develop an open
and trusting relationship.
To maximize the communication benefits it is important that emission registers focus on
reporting of those substances whose hazard characteristics and probable release quantities
suggest a need for surveillance and control.
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Benefits to Government and Local Authorities
Information on emissions of materials can enable governments to design an efficient
management regulatory framework. In particular, governments can use emission
information to develop strategies for substances, industries or regions that require the
most attention.
Chapter 19 of Agenda 21 identifies information gathering and dissemination about
chemical emissions as a basic element for the sound management of chemicals and
specifically advocates the establishment of national emission inventories. This can most
usefully be done through the development of reporting systems, which include emissions
from chemical factories in the totality of emissions from industry and other sources.
The challenge facing governments is to design an effective, yet manageable emission
reporting system. Because environmental issues and priorities vary between countries and
regions, emission-reporting programs must be tailored to meet local, regional or national
conditions. Ideally, emission reporting is not limited to industrial emissions, going
beyond industrial releases and also considering environmental emissions from other
sources, including diffuse ones derived from transportation, agriculture and housing.
However, each country must decide how much information is needed; where it should be
collected; what are the costs involved in collecting, maintaining and disseminating the
information; and what are the ultimate goals of the program.
Governments should give careful consideration to the range of substances for which they
require reporting. Ideally, emission reporting programs should target a manageable
number of substances that pose the greatest concern from a relative risk standpoint,
thereby focusing on priority concerns and limiting reporting and data management costs.
Emission reporting programs can become burdened by an excessive number of chemicals
of limited public relevance resulting in rising costs to both industry and government with
limited return in useful information.
Countries should also consider the possibility of starting their PRTR national scheme as a
voluntary program that could be used as a model to understand the difficulties involved in
collecting and reporting emission data. Based on the results from such a voluntary
initiative, a mandatory national PRTR could be better established.
Benefits to the Public
Emission reporting programs enhance the public’s awareness and understanding about
emissions in their communities. The availability of emission information provides the
public with a tool to communicate with industry and government. The challenge to the
public is to understand the benefits and limits of emission reporting information. The
information needs to be considered in context and can inadvertently be overextended,
most notably by using it as a surrogate for risk.
Some public interest groups - particularly in the United States - have called for expansion
of emission reporting requirements: more substances without any clear rationale, lower
reporting thresholds, and collection of material use information. They advocate that more
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information will result in a more informed public. However, the key to reporting PRTRs
is to focus on those substances that have the greatest potential to harm the environment
and track environmental performance by showing where and why emissions are reduced.
ICCA PRINCIPLES FOR EMISSION INVENTORIES

ICCA supports and promotes development and use of properly designed emission
inventories.

The Responsible Care® program aims at continuous improvement, including longterm reductions in the amount of all releases to air, water and land; and continuous
reductions in the amount of wastes generated at facilities.

In developing or refining an emission reporting program, countries should focus on
their own needs by targeting a baseline set of substances that are of national concern
and collect data from point and non - point source activities that may generate
emissions.

An emission reporting program should seek to achieve the following basic objectives:



document and stimulate emission reduction;
provide data that enhances government and industry management of chemicals;
and,
provide the public with information that will improve their awareness and
understanding of chemical emissions in their communities.

Emission reporting programs should be effective, manageable and concentrate on
reporting requirements that provide real benefits without imposing unnecessary costs
upon government, industry and society as a whole.

Emission reporting programs should focus reporting on a moderate number of
substances, whose hazard characteristics and probable release quantities suggest a
need for surveillance and control and for which set threshold values are exceeded.
Reporting should be as simple as possible to not unreasonably burden reporting
facilities and the level of detail should be commensurate with the use of the data.

Emission reporting programs should focus on environmental releases, not on in-plant
processing or materials use.

The benefits and limits of emission reporting information must be widely understood.
When properly used, emission reporting can be extremely useful in communication
and in improving industry’s environmental performance. However, there is a
tendency to overextend the application of emission reporting data, most notably by
using the information as a surrogate for risk.
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