INTERNATIONAL
COUNCIL OF
CHEMICAL
ASSOCIATIONS
8 August 2001
ICCA COMMENTS ON
USE OF POLLUTANT RELEASE AND TRANSFER REGISTER
(PRTR) DATA
INTRODUCTION
Background
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
coordinates Responsible Care® and other voluntary chemical industry initiatives. The
chemical associations in forty-five countries implement ICCA’s Responsible Care®
initiative.
In September 2000 the ICCA published a paper setting out its comments on Pollutant
Release and Transfer Register (PRTR) programs. The principal statement made in the paper
is the following:
The International Council of Chemical Associations (ICCA) supports emissions
reporting and believes that these programs can provide valuable information that can
help document and stimulate reduction in emissions and communicate information to key
audiences.
The September 2000 paper focused on the benefits of emission reporting, including benefits
to industry, government and local authorities, and the public. The paper also listed a series
of emission inventory principles supported by the ICCA.
Purpose
This paper serves as a companion to the ICCA’s September 2000 paper by focusing on the
legitimate uses of PRTR data to meet the information needs of the public by placing
emissions data into a risk context.
The paper highlights the importance of ensuring that the public has confidence in the
emissions data. It describes how emissions data are currently communicated by national
industry associations and companies. The paper also addresses the link between emissions
data and risk information, and provides examples of both helpful and questionable
approaches.
INFORMATION STEWARDSHIP PRINCIPLES
Emissions data are core sets of information used by national and international organizations
as well as individual companies and facilities to document performance in emissions
reduction and to communicate with key audiences. In order to maximize their use as a
performance measure and a communication tool, the data should be placed in a context
describing the proper interpretation of the information. While there are several challenges in
doing so, many of these can be met by using good information stewardship principles.
The establishment of a national or regional emission inventory program will result in an
information resource of use to many audiences. To be effective, the information resource
must be maintained by an organization – a unit of government, trade association or other
group -- that is trusted and respected.
An organization that intends to be a trusted supplier of environmental information to the
public should assume responsibilities of “information stewardship,” a concept derived by
analogy from the chemical industry’s Responsible Care concept of product stewardship.
Under product stewardship, the manufacturer of a tangible product makes health, safety and
environmental protection an integral part of the product’s life cycle. It does this in part by
identifying reasonably foreseeable exposures to the product’s hazards and providing
information to enable the product to be used safely.
When an organization compiles, analyzes and disseminates information in a report or
website, it is creating an “information product.” The concept of information stewardship
requires such an organization to identify the reasonably foreseeable ways an information
product may be misunderstood or misused, and to take those possibilities into account in
designing and packaging the information product. In the case of PRTR data, therefore, the
essence of this stewardship responsibility is the provision of information about emissions
data in a form that is accurate and likely to be properly understood by the customer.
A basic requirement is accuracy of the data. When dealing with a large volume of data there
is a strong likelihood of errors occurring. The key is for the information steward to have a
commitment to improvement and a process by which errors can be corrected and the
database continually upgraded.
The first task for the information steward is to define the purpose and audience for the
information product that is being developed or maintained. Once the purpose and audience
for a product is defined, then the following questions can be answered:

What is the level of data accuracy needed for the emission inventory and how can it
be ensured?
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
What context is needed, in terms of scientific, technical, operational or program
background information, for the audience to understand the meaning of the emission
inventory data?

What process steps, such as public comment and stakeholder review, are appropriate
for the type of information?
Based on its purpose and audience, and the answers to these questions, an information
product using PRTR data can be responsibly developed.
INDUSTRY USE AND COMMUNICATION OF EMISSIONS DATA
Emissions data are widely used by industry as a key performance indicator for measurement
and communication. The data are important to industry because they track how a facility or
company is managing its emissions to the environment. This information is important to
outside audiences – government, environmental organizations, and the general public –
because it can be a quantified measure of environmental improvement. Thus, most chemical
companies collect emissions data and many publish them in annual reports or post them on
facility web sites.
Emissions data should be made available to the public. There is no single best way to
present emissions information to the public. Rather, it depends on the culture and traditions
of the particular country. Companies have successfully used various methods to
communicate emissions data, including published reports, community meetings, visits to the
facility and web sites.
The most common way of disseminating emissions data is through written reports. Many
ICCA members issue annual documents that address performance indicators – including
emissions reduction -- and have mechanisms for communicating with interested parties. In
addition, several individual chemical associations publish Responsible Care® reports that
provide detailed information on emissions reduction performance and trends. Increasingly
these reports are available through the organization’s corporate web site.
Emissions data are often most effectively presented and discussed in person. Many ICCA
member companies have established community advisory panels that meet on a regular basis
and discuss performance issues, including emissions reductions.
PLACING EMISSIONS DATA IN A RISK CONTEXT
The ICCA believes that emissions data should be easily accessible, thereby increasing their
use by government, the public and industry. The different sectors can and do use the data in
a variety of ways. For example, industry uses the data to document and stimulate reduction
in emissions and communicate information to key audiences; governments use the data to
design an efficient regulatory framework; and the public uses the data to understand
emissions in their communities.
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The ICCA supports these and other uses of the data, provided that the limitations of the
information are recognized and clearly communicated. This is particularly important when
emissions data are placed into a risk context, as is being increasingly attempted by regulatory
agencies and other organizations.
In order to maximize its use as a performance measure and a communication tool, emissions
data should be placed in context. Currently, the most common context provided is a trend
analysis in which emissions data are presented over a three to five year timeframe that allows
the reader to determine whether emissions have decreased. Many companies also provide
emission reduction goals as well as statistics such as number of employees and units of
production that provide an indication of the size of the facility.
The public is often interested in knowing more than simply whether emissions have
increased or decreased over time. Increasingly, they want answers to questions such as “do
emissions place me at risk?” Industry and government are attempting to answer such
questions, and emissions data can help. Although emissions data alone are not sufficient to
quantify actual risks posed to public health from any single facility, they can be used to
provide important information for risk-related questions.
The ICCA supports use of scientifically valid risk assessment methods for evaluating and
prioritizing health, safety and environmental risks (Principles for Risk Based Decision
Making, June 1995). However, to conduct a risk assessment it is necessary to have a full
range of information, well beyond simply emissions data. The ICCA supports the “use of all
valid scientific data regarding human health, hazard and exposure, including long- term fate
of our products, in conducting risk assessments.”
When communicating emissions data in a risk context it is essential that the following risk
concepts be fully explained, to ensure an understanding that it is the combination of these
factors (not one factor in isolation) that determines the risk.
Toxicity. Some substances are more toxic than others and have more potential to harm
human health or the environment. The toxic potency of substances reported under most
PRTRs can vary considerably. Thus, one substance may be emitted in greater volume than
another but may not pose as significant a risk due to the differences in toxicity.
Environmental Fate. Some substances remain in the environment longer than others and
are transported differently in air, water and in the soil. Some substances may quickly break
down into simpler, less toxic forms; others may accumulate in the environment, becoming a
potential source of long-term exposure.
Exposure Potential. The likelihood that an environmental receptor (fish, wildlife, plant
species, human) will come into contact with a substance that is emitted depends on where the
emission source is located, how the substance is transported and its environmental fate,
which affects the method and likelihood of uptake. Exposure potential is also affected by the
receptor’s activities, location and diet.
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Emissions data provide only one of the factors that need to be taken into account in assessing
risk to humans or wildlife: the amount of a substance that is put into the environment from
particular sources in a given time period. In most cases, even that information is incomplete
because major sources of the same substance are not included in the PRTR. Most PRTRs
include emissions data only from industrial facilities and do not include emissions from
transport, commercial or domestic sources. For many substances these other sectors account
for a significant, or even the major, proportion of total emissions.
When emissions data are placed in a risk context, attempts are sometimes made to assign a
relative score or weight to each substance based on toxicity, environmental fate and
exposure potential. However, any such weighting scheme will contain a significant number
of default assumptions, uncertainties, and biases that limit its use. These assumptions are
made to fill in gaps about toxicity, fate, or exposure potential. Most importantly, the
assumptions must be thoroughly communicated to audiences and the limitations of this
approach should be clearly stated.
Example of Emissions Data in a Risk Context
In the Netherlands, government, academia and the chemical industry association (VNCI) are
collaborating to develop an environmental measure that could effectively communicate the
impact of emissions. The parties recognized that simply reporting annual emissions provides
little insight into the environmental impact of the substances emitted, particularly since the
substances possess different toxicities. It was recognized that what was needed was an
unambiguous method that rendered the environmental impact of the emissions
understandable.
In 1999, the VNCI began a collaborative effort with the Centre for Energy and Conservation
and Environmental Technology (CE Delft) and the Centre of Environmental Science (CML)
of Leiden University that resulted in the development of the Environmental Theme Key
Figure method. The method consists of seven environmental themes that comprise
categories of environmental impacts that may occur as a result of the discharge of emissions
to the air or waters.
The use of the method results in a more risk-based presentation of the annual reductions in
emissions achieved by the chemical industry. In addition, the Ministry of Housing, Spatial
Planning and the Environment will also deploy the method, which may result in a new
prioritization of the environmental objectives to be achieved by the chemical industry.
The U.S. EPA developed a tool – the Risk-Screening Environmental Indicators (RSEI)
Model – that is designed to assist the agency in ranking and screening air emissions data
submitted under the Toxic Release Inventory. The stated purpose of RSEI is to provide “a
screening-level, risk-related perspective for relative comparisons of chemical releases.”
RSEI contains a significant number of default assumptions, uncertainties, and biases that
limit its use, and the documentation associated with RSEI provides frequent caveats and fully
describes the limitations of the tool.
RSEI undoubtedly can be useful as a mechanism for placing emissions data into context,
provided that the user understands the documented caveats and limitations. However, the
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RSEI tool can be run without reviewing the documentation provided, and the results can be
exported to other software packages, printed, inappropriately modified, and presented out of
context.
Some environmental organizations have used emissions data in models that rely on exposure
and toxicity factors imported from RSEI and the State of California. Such models, by
extrapolating the available information beyond its purpose, violate good stewardship
principles and thus mischaracterize the information. Most importantly, they do not clearly
communicate the limitations of the data and the calculations. Despite all the caveats
regarding the use of RSEI, the environmental organizations extracted surrogate dose data and
calculated individual added cancer risks for facilities with emissions data. Some of the
limitations are described and links provided to the RSEI website, but most caveats and
limitations are secondary to the presentation of cancer risks.
Emissions data should be easily accessible and used by government, the public and industry.
Different sectors can and do use the data in varying ways. However, any organization that
places emissions data in a risk or performance based context needs to ensure that good
information stewardship principles are followed.
ICCA PRINCIPLES FOR THE USE OF EMISSION INVENTORY DATA

ICCA supports emissions reporting and believes that these programs can provide
valuable information that can help document and stimulate reduction in emissions
and communicate information to key audiences.

The public must feel confident that emissions data is collected, managed and
disseminated in a responsible manner. The unit of government, trade association or
company that collects and manages emissions data must agree to follow basic
stewardship principles, including:



Define the purpose and the audience for the data.
Ensure that the information is accurate and that a process exists for making
corrections.
Provide a proper context for the information so that it can be correctly
understood by intended audiences.

Health, safety and environmental information are used throughout the chemical
industry to establish performance goals and measure progress. Emissions data are
core sets of information that are used by national and international organizations as
well as individual companies and facilities to document performance and to
communicate with key audiences.

Emissions data should be made available to the public. There is no single best way to
present emissions information to the public. Rather, it depends on the culture and
traditions of the country. Trade associations and companies have successfully used
several different methods to communicate emissions data, including published
reports, web sites, community meetings and visits to the facility.
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
In order to maximize its use as a performance measure and a communication tool,
emissions data should be placed in context. Currently, the most common context
provided is a trend analysis in which emissions data are presented over a three to five
year timeframe that allows the reader to determine whether emissions have
decreased. Many companies also provide emission reduction goals, as well as
statistics -- such as number of employees and units of production -- that provide an
indication of the size of the facility.

Emissions data provide only one of the factors that need to be taken into account in
assessing risk to humans and wildlife.

Several governments and other organizations have attempted to place emissions data
into a risk context. Such attempts are understandable because the public wants riskrelated information. However, it is essential that good information stewardship
principles be followed. Most importantly, the limitations of emissions data must be
clearly recognized and communicated.
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