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Chemical Safety in a Vulnerable World
IFCS/FORUM-IV/6 INF
Original: English
16 April 2003
FORUM IV
Fourth Session
of the
Intergovernmental Forum on Chemical Safety
Bangkok, Thailand
1 – 7 November 2003
************************************
Ongoing and future Pollutant Release and Transfer
Registries (PRTRs) capacity building projects that the
International Council of Chemical Associations (ICCA)
has been involved with or supported
Prepared by: ICCA
For the protection of the environment and reasons of economy, this document is printed in limited number.
Delegates are kindly requested to bring their copies to the meeting and not to request additional copies
Secretariat: c/o World Health Organization, 20 Avenue Appia, CH-1211 Geneva 27, Switzerland
Tel: +41 (22) 791 3873/3650; Fax: +41 (22) 791 4875; Email: [email protected]; Website: www.ifcs.ch
INTERGOVERNMENTAL FORUM ON CHEMICAL SAFETY
Fourth SESSION – FORUM IV
1-7 November 2003
IFCS/FORUM-IV/6 INF
INTERNATIONAL
COUNCIL OF
CHEMICAL
ASSOCIATIONS
REPORT TO FORUM IV
BANGKOK, THAILAND NOVEMBER 2003
ONGOING AND FUTURE POLLUTANT RELEASE AND TRANSFER REGISTRIES
(PRTRs) CAPACITY BUILDING PROJECTS
THAT THE INTERNATIONAL COUNCIL OF CHEMICAL ASSOCIATIONS
(ICCA) HAS BEEN INVOLVED WITH OR SUPPORTED
The ICCA has developed two detailed papers on Pollutant Release and Transfer Registries
(PRTRs), namely “ICCA Comments on Pollutant Release and Transfer Registers (Sept
2000)” and “ICCA Comments on Use of Pollutant Release and Transfer Register Data (Aug
2001)”. ICCA has clearly stated that it 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.
ICCA members have worked closely with a number of governments to develop national
emissions reporting programs. We see these as complementary to reporting provisions of
Responsible Care. As with Responsible Care, our experience is that PRTR programs
need to be able to vary considerable from country to country, but should be based on certain
basic concepts and guiding principles. Designed in this manner, our experience has been that
there are benefits of emissions reporting to industry, governments and local authorities, and
to the public.
Specific principles that ICCA has promoted for capacity building in the development of
emissions inventories are:
 ICCA supports and promotes development and use of properly designed emission
inventories.
 The Responsible Care® program aims at continuous improvement, including long-term
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.
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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.
ICCA has been involved in promoting the spread of appropriately designed PRTRs as
described above and has done so by participating in and supporting a number of international
activities including:
 PRTR special session at Forum III in Bahia, Brazil
 workshops to promote PRTRs in Chili and the Caribbean
 participation in IOMC PRTR Coordinating Group
 participation in UNECE discussions on development of PRTR protocol.
ICCA specifically endorses the guidance provided on PRTRs developed at Forum III in
Bahia, Brazil namely:
“Pollutant Release and Transfer Registers (PRTRs) / emission
inventories are recognized in Chapter 19 of Agenda 21 as an important
tool to raise public awareness about potential chemical risks and as an
effective environmental management tool to stimulate chemical risk
reduction. Although PRTRs are designed to be country-specific, there
are commonalities between national systems. Common characteristics of
many successful PRTR programmes include:
 a listing of pollutant;
 environmental multi-media and / or integrated reporting of releases and
transfers (i.e. to air, water, and land);
 reporting of data by source;
 reporting of data periodically (normally annually); and
 making data and information available to the public.”
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1-7 November 2003
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Attachments:
ICCA Comments on Pollutant Release and Transfer Registers (Sept 2000)
ICCA Comments on Use of Pollutant Release and Transfer Register Data (Aug 2001)
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Fourth SESSION – FORUM IV
1-7 November 2003
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INTERNATIONAL
COUNCIL OF
CHEMICAL
ASSOCIATIONS
ICCA COMMENTS ON
POLLUTANT RELEASE AND TRANSFER
REGISTER (PRTR)
19 September 2000
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), 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.
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Benefits to Industry
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.
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
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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 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.
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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
long-term 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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Fourth SESSION – FORUM IV
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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.
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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.
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.
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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.
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.
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
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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
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.
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Fourth SESSION – FORUM IV
1-7 November 2003
IFCS/FORUM-IV/6 INF
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.

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 risk-related 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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