Toxic Substances: Few States Have Considered Reporting Requirements for
Chemical Use Data (Letter Report, 06/06/97, GAO/RCED-97-154).

Pursuant to a congressional request, GAO: (1) identified which states
have had legislative bills or voter referendums from January 1991
through February 1997 that would have required the reporting of chemical
use data and described the disposition of these proposals; and (2)
discussed the findings of studies on the advantages and disadvantages of
requirements to report chemical use data.

GAO noted that: (1) while two states, Massachusetts and New Jersey,
require industries to report chemical use data, few other states have
introduced legislation that would require such reporting; (2) for the
period January 1, 1991, through February 28, 1997, GAO identified only
12 bills introduced in six different states that would have required
industries to report chemical use data; (3) bills were introduced in
California, Colorado, Florida, Hawaii, Maryland, and Michigan but not
enacted; (4) in GAO's survey of the 50 states and the District of
Columbia, GAO found no ballot initiatives or voter referendums that
would have required industries to report chemical use data; (5) GAO
identified several studies and reports that discuss the advantages and
disadvantages of implementing requirements to report chemical use data;
(6) interest groups, state agencies, and state-sponsored research
institutes in Massachusetts and New Jersey have written reports and
studies discussing the progress of programs that require reporting of
chemical use data in those states; (7) these studies have reported
positive impacts, such as more efficient use of toxic chemicals by
industries; (8) however, they have also reported some problems in
administering the programs and obtaining accurate data from industries;
(9) in addition, one study, conducted by the Minnesota Office of Waste
Management, concluded that the burden on the state's industries
outweighed the benefits of requiring the reporting of chemical use data;
(10) several studies by nongovernmental organizations have focused on
the advantages of collecting chemical use data, such as assisting
pollution prevention efforts, providing information to citizens on the
actual amount of toxic chemicals present in their communities, and
assisting emergency planning efforts; (11) on the other hand, some
nongovernmental studies have concluded that providing such information
could jeopardize industrial trade secrets, that the reporting
requirements would be costly and time-consuming, and that the
information reported may be underutilized; and (12) the Environmental
Protection Agency has reported similar advantages and disadvantages of
reporting on chemical use data.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-97-154
     TITLE:  Toxic Substances: Few States Have Considered Reporting 
             Requirements for Chemical Use Data
      DATE:  06/06/97
   SUBJECT:  Reporting requirements
             Toxic substances
             State legislation
             State programs
             Pollution control
             Industrial wastes
             Environmental policies
             Industrial facilities
IDENTIFIER:  Massachusetts
             New Jersey
             California
             Colorado
             Florida
             Hawaii
             Maryland
             Michigan
             EPA Toxic Release Inventory
             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Oversight and Investigations,
Committee on Commerce, House of Representatives

June 1997

TOXIC SUBSTANCES - FEW STATES HAVE
CONSIDERED REPORTING REQUIREMENTS
FOR CHEMICAL USE DATA

GAO/RCED-97-154

Chemical Use Data

(160373)


Abbreviations
=============================================================== ABBREV

  EPA - Environmental Protection Agency
  EPCRA - Emergency Planning and Community Right-to-Know Act of 1986
  TRI - Toxics Release Inventory

Letter
=============================================================== LETTER


B-276855

June 6, 1997

The Honorable Joe Barton
Chairman, Subcommittee on Oversight
 and Investigations
Committee on Commerce
House of Representatives

Dear Mr.  Chairman: 

In its October 1996 advance notice of proposed rulemaking, the
Environmental Protection Agency (EPA) reported that it was
considering requiring industries to report the amounts of toxic
chemicals entering a facility, transformed into products and waste,
and leaving the facility.  This concept has been referred to as
"materials accounting" or "chemical use data" (hereafter referred to
as chemical use data).  This proposed requirement would expand the
amount and type of information that industries are currently required
to report. 

To help assess the need for a federal requirement to report chemical
use data, you asked us to identify state actions related to
requirements on chemical use data.  As agreed with your office, this
report (1) identifies which states have had legislative bills or
voter referendums from January 1991 through February 1997 that would
have required the reporting of chemical use data and describes the
disposition of these proposals and (2) discusses the findings of
studies on the advantages and disadvantages of requirements to report
chemical use data. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

While two states--Massachusetts and New Jersey--require industries to
report chemical use data, few other states have introduced
legislation that would require such reporting.  For the period
January 1, 1991, through February 28, 1997, we identified only 12
bills introduced in six different states that would have required
industries to report chemical use data.  Bills were introduced in
California, Colorado, Florida, Hawaii, Maryland, and Michigan but
were not enacted.  In our survey of the 50 states and the District of
Columbia, we found no ballot initiatives or voter referendums that
would have required industries to report chemical use data. 

We identified several studies and reports that discuss the advantages
and disadvantages of implementing requirements to report chemical use
data.  Interest groups, state agencies, and state-sponsored research
institutes in Massachusetts and New Jersey have written reports and
studies discussing the progress of programs that require reporting of
chemical use data in those states.  These studies have reported
positive impacts, such as more efficient use of toxic chemicals by
industries.  However, they have also reported some problems in
administering the programs and obtaining accurate data from
industries.  In addition, one study, conducted by the Minnesota
Office of Waste Management, concluded that the burden on the state's
industries outweighed the benefits of requiring the reporting of
chemical use data.  Several studies by nongovernmental organizations
have focused on the advantages of collecting chemical use data, such
as assisting pollution prevention efforts, providing information to
citizens on the actual amount of toxic chemicals present in their
communities, and assisting emergency planning efforts.  On the other
hand, some nongovernmental studies have concluded that providing such
information could jeopardize industrial trade secrets, that the
reporting requirements would be costly and time-consuming, and that
the information reported may be underutilized.  EPA has reported
similar advantages and disadvantages of reporting on chemical use
data. 


   BACKGROUND
------------------------------------------------------------ Letter :2

On October 1, 1996, EPA published an advance notice of proposed
rulemaking in the Federal Register,\1 stating that the agency is
considering expanding the Toxics Release Inventory (TRI) database to
require the reporting of chemical use data.  The expanded database,
referred to as "TRI phase III," is intended to provide the public
with a more comprehensive picture of industries' environmental
performance as well as more complete and accurate information on the
toxic chemicals that are present in communities.  With more complete
information, TRI phase III is intended to (1) increase industries'
ability to use toxic chemicals more efficiently and ultimately reduce
the amount industries use and (2) enable the public to be more
knowledgeable when participating in environmental decision-making. 
The comment period for EPA's advance notice of proposed rulemaking
ended February 28, 1997, and EPA expects to propose a rule on
reporting chemical use data in 1998.  In May 1997, two bills were
introduced in the Congress (H.R.  1636 and S.  769) that would
require the reporting of chemical use data. 

Industries that produce or use toxic chemicals are already required
to report releases of such substances.  Specifically, the Emergency
Planning and Community Right-to-Know Act of 1986 (EPCRA) requires
planning for chemical emergencies and provides citizens with access
to information on the presence and release of toxic chemicals within
their communities.  The act generally requires facilities at which
toxic chemicals are manufactured, processed, or otherwise used to
report annually to EPA and the states on the releases of these
substances.  The requirement applies to facilities with 10 or more
full-time employees in specified manufacturing sectors that
manufacture, process, or use designated toxic chemicals in excess of
certain thresholds.  These data are published by EPA in the TRI.  In
addition, the Pollution Prevention Act of 1990 expanded the
information collected in the TRI to include data on source reduction
and recycling.  The act requires facilities subject to the EPCRA's
reporting requirements to provide information on the amount of toxic
chemicals they treat and recycle both on- and off-site.  In November
1994, EPA further expanded the data included in the TRI by requiring
additional chemicals to be reported; and, in June 1996, EPA proposed
adding additional industrial groups, such as coal mining and electric
utilities, that would be required to report information for inclusion
in the TRI.  This proposal was made final and announced in the
Federal Register on May 1, 1997. 

To identify state bills, referendums and ballot initiatives, and
their disposition, we conducted a telephone survey of all 50 states
and the District of Columbia, contacted knowledgeable officials at
EPA, and conducted searches of legislative databases.  To identify
studies on the advantages and disadvantages of requirements to report
chemical use data, we contacted EPA headquarters officials, EPA's
regional TRI representatives, and each of the state TRI
representatives.  We also contacted industry groups, public interest
groups, and national organizations. 


--------------------
\1 61 Fed.  Reg.  51322. 


   FEW STATES HAVE CONSIDERED
   PROPOSALS REQUIRING THE
   REPORTING OF CHEMICAL USE DATA
------------------------------------------------------------ Letter :3

Few states have had proposals that would require the reporting of
data on chemical use.  We identified only 12 bills introduced from
January 1, 1991, through February 28, 1997, in six different state
legislatures that would have required industries to report
information on chemical use.  As of April 15, 1997, none of these
bills had been enacted with a requirement to report chemical use
data.  In our survey of the 50 states and the District of Columbia,
we found no ballot initiatives or voter referendums that would have
imposed such a requirement.  Two states--Massachusetts and New
Jersey--enacted legislation prior to 1991 that requires the reporting
of such information. 

During the period covered by our analysis, bills that would have
required industries to gather and publicly disseminate information on
chemical use were introduced in California, Colorado, Florida,
Hawaii, Maryland, and Michigan.  Michigan accounted for 4 of the 12
bills, Florida for 3, and California for 2.  The remaining states had
one bill each.  The bills generally would have required industries to
report periodically on the amount of hazardous or toxic substances,
entering, generated at, used at, and leaving their facilities.  For
example, a bill introduced in one state would have required
industries to report, among other things, the quantities of the toxic
or hazardous substances at their facilities that are (1)
manufactured, processed, or otherwise used; (2) generated as a
by-product in certain circumstances; or (3) shipped from the
facilities.  While the language of the other bills differed somewhat,
they were generally consistent with this example. 

Seven of the 12 bills were not enacted after initial referral to a
committee or committees.  Of the other five bills, one was withdrawn
from consideration before being referred to a committee; action on
another was postponed indefinitely; one failed in the legislative
house in which it was introduced; action was taken in committee on
one, but ultimately it did not pass; and one was enacted but without
the requirement to report chemical use. 

Finally, none of the officials we contacted in the 50 states and the
District Columbia were aware of ballot initiatives or voter
referendums that would have required the reporting of chemical use
information.  Although one state official told us that her state had
considered such an initiative, available information indicates that
this initiative would have required the labeling of certain products
as containing toxic or hazardous substances but would not have
required facilities to disclose chemical use information. 

Prior to 1991, Massachusetts and New Jersey had established programs
requiring reporting of chemical use data.  In Massachusetts, the
Toxics Use Reduction Act of 1989 requires users of toxic chemicals
(above certain thresholds) to report annually, among other things,
the quantities of each toxic substance manufactured, processed, or
otherwise used.  New Jersey has been collecting chemical use
information from industries, such as manufacturing and utilities,
since 1987 under the Worker and Community Right-to-Know Act of 1984,
as amended.  The law requires businesses to submit an environmental
survey to the state each year.  The environmental survey contains,
among other things, data on the quantities of hazardous substances
produced, brought into, consumed, shipped out, and emitted from a
facility. 


   STUDIES REVEAL BOTH ADVANTAGES
   AND DISADVANTAGES TO REPORTING
   CHEMICAL USE DATA
------------------------------------------------------------ Letter :4

We identified several studies and reports concerning the advantages
and disadvantages of reporting chemical use data.  These included
about 10 studies and reports regarding the progress of programs in
Massachusetts and New Jersey.  We also identified one study by
Minnesota and approximately 10 studies and issue papers by
nongovernmental entities that reviewed the advantages and/or
disadvantages of reporting chemical use data.  (See the bibliography
for the studies we reviewed.) Studies on the Massachusetts and New
Jersey programs generally reported that there have been benefits from
the reporting requirements but that there have also been some
problems in implementing and managing the state programs.  The
Minnesota study concluded that the disadvantages of implementing a
statewide requirement to report chemical use data would outweigh the
benefits.  Some studies by nongovernmental entities reported the
advantages of such a reporting requirement, including the need for
this information to assess industries' pollution prevention efforts. 
Other studies reported disadvantages, such as the possibility that
the disclosure of such information could reveal industrial trade
secrets and that the reporting would be burdensome to industries. 
EPA's issue papers and its advanced notice of proposed rulemaking
also discussed these advantages and disadvantages. 


      STUDIES ON THE PROGRESS OF
      PROGRAMS IN MASSACHUSETTS
      AND NEW JERSEY TO REPORT
      CHEMICAL USE DATA
---------------------------------------------------------- Letter :4.1

The studies conducted or sponsored by Massachusetts and New Jersey on
their programs reported that the requirements to report chemical use
data have mainly produced benefits.  The studies found that
industries in those two states more efficiently used toxic chemicals. 
For example, one Massachusetts study reported that, although the
actual amounts of chemicals used and chemical by-products have
increased from 1990 through 1994, when adjusted for increases in
production, there was a downward trend.  New Jersey's Department of
Environmental Protection also found a trend toward more efficient
chemical use by industries that use toxic chemicals, such as
chemical, paper, and pharmaceutical companies.  It reported an
overall decline in chemical by-products since 1990--chemical
by-products are the hazardous substances associated with the
production process that are not part of the final product.  The study
also pointed out that other factors could explain the improvements. 
For example, the overall emphasis on pollution prevention in New
Jersey since the late 1980s and the state's history of strict
environmental laws and vigorous enforcement were cited as possible
factors for the reduction in chemical by-products.  In addition, the
state studies reported other benefits to reporting chemical use data,
such as helping the states track the progress of pollution prevention
by their industries. 

The studies also described some difficulties in carrying out
requirements to report chemical use.  Studies on both the
Massachusetts and New Jersey state programs found inconsistencies and
inaccuracies in the data reported by industries, particularly in the
beginning of the programs.  For example, reporting requirements were
misunderstood, and clerical and mathematical errors occurred in the
reporting.  In addition, for some industries, reporting an exact
value for the amounts of chemicals is not feasible.  For example,
according to a report by the New Jersey Department of Environmental
Protection, the petroleum-refining industry must report chemicals in
crude oil as a range of numbers because the amounts of chemicals vary
within the raw material.  Reports on the program in Massachusetts
indicated some problems in making the data accessible to the public
at the onset of the program in 1990.  However, according to a 1996
report, placing Massachusetts' chemical use data on the Internet
provided greater public access. 


      MINNESOTA STUDY ON THE PROS
      AND CONS OF REPORTING
      CHEMICAL USE DATA
---------------------------------------------------------- Letter :4.2

One study completed by the Minnesota Office of Waste Management
concluded that a statewide requirement to report chemical use data
would place an additional burden on industries and that the data
already being reported by industries had not been fully utilized. 
Although the study considered the potential benefits of reporting
chemical use data, it pointed out that the burden of additional
reporting may interfere with industries' progress under that state's
pollution prevention program because the requirement could take time
and resources away from pollution prevention efforts.  The study
concluded that the goals of reporting chemical use data would be
better addressed through other means, such as programs to assist
industries in reducing the amounts of chemicals they use and in
preventing chemical spills.  The study also stated that the
information that industries are currently required to report under
state laws and the Pollution Prevention Act of 1990 is not fully
utilized and recommended using resources to improve public access and
to make better use of the data that are currently being collected. 


      ADVANTAGES AND DISADVANTAGES
      OF A NATIONWIDE REQUIREMENT
      TO REPORT CHEMICAL USE DATA
      CITED BY NONGOVERNMENTAL
      STUDIES
---------------------------------------------------------- Letter :4.3

Some studies conducted by nongovernmental entities reported
advantages to requiring the reporting of chemical use data, including
the benefits of more complete information than the information that
is already reported under TRI requirements.  The main advantage to
reporting these data, as cited in the studies, was their utility for
accurately assessing industries' pollution prevention efforts. 
According to proponents of this requirement, the data are needed to
assess whether industries are actually using toxic chemicals more
efficiently or changing their procedures so that it appears that they
are more efficient.  For example, the studies point out that
facilities could reduce the amount of releases of toxic chemicals
they report by changing their accounting practices or reducing
production.  According to a study that analyzed industrial production
data in New Jersey's program, pollution prevention activities could
not be confirmed by toxic release information alone, and chemical use
data were needed to verify that pollution prevention had occurred. 
In addition, the studies discussed the value of chemical use data for
informing the public, worker safety, and emergency preparedness
planning, as well as helping facilities more efficiently manage their
operations by reducing the amounts of chemicals used. 

The disadvantages of a nationwide requirement to report chemical use
data, as cited in the studies, included potential adverse impacts on
industries that would be required to report this information.  The
main negative impact reported in these studies was the disclosure of
confidential business information and the potential loss of
industries' competitive advantage against their competitors in the
United States and abroad.  The studies pointed out that the chemical
use data, along with other information on a facility, could provide
competitors with an opportunity to obtain the trade secrets of that
facility.  One study indicated that international competitiveness may
be of particular concern because the confidentiality of business
information is more strictly maintained in Japan and Europe.  Other
disadvantages cited in these studies were the time and resources
required to calculate and prepare chemical use reports.  Industry
groups have also questioned the utility of providing chemical use
data because of their belief that current TRI data are not fully
utilized. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

We provided copies of a draft of this report to EPA for review and
comment.  EPA generally agreed with the facts presented in the draft
report.  The Director of the Environmental Assistance Division,
within the Office of the Assistant Administrator for Prevention,
Pesticides, and Toxic Substances, however, provided a few technical
revisions that we have incorporated into the report as appropriate. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :6

Our objectives were to (1) identify which states have had bills or
voter referendum from January 1991 through February 1997 that would
have required the reporting of chemical use data and the disposition
of these proposals and (2) discuss the findings of studies on the
advantages and disadvantages of requirements to report chemical use
data.  We chose January 1, 1991, as a starting point because that
date was the beginning of the first full legislative session for the
states after enactment of the Pollution Prevention Act of 1990 and
because of concerns about the reliability of information on state
bills prior to that date. 

To obtain a comprehensive list of state bills, referendums, and
ballot initiatives from January 1, 1991, through February 28, 1997,
along with their disposition, we conducted a telephone survey of all
50 states and the District of Columbia, contacted knowledgeable
officials at EPA, and conducted database searches.  In our telephone
survey, we interviewed the designated TRI contact person for each
state and the District of Columbia and contacted other knowledgeable
state officials that were recommended by these contact persons.  We
interviewed EPA headquarters officials involved with TRI and each of
EPA's 10 regional TRI coordinators.  We conducted searches on the
LEXIS and Westlaw legal databases to corroborate the information we
obtained from federal and state officials as well as to obtain
additional information regarding the existence, status, and final
disposition of relevant bills.  We also conducted searches on the
Internet to identify studies on the advantages and disadvantages of
reporting chemical use data.  During our work, state officials told
us of several bills that, upon further review, would not have
required facilities to report information on chemical use.  In other
cases, we were provided information about proposed legislation but we
could not locate a copy of the bill.  We included only those bills
that we could confirm included requirements to report chemical use
data by reviewing the actual text of each bill.  In addition, we
reviewed EPA's docket on its advance notice of proposed rulemaking
after the comment period ended on February 28, 1997. 

To identify studies on the advantages and disadvantages of
requirements to report chemical use data, we contacted EPA
headquarters officials, EPA's 10 regional TRI representatives, and
each of the states' and the District of Columbia's TRI
representatives.  In addition to the above-mentioned contacts and
searches for studies, we contacted industry groups, public interest
groups, and national organizations (see app.  I).  Our work was
performed in accordance with generally accepted government auditing
standards from January through April 1997. 

As arranged with your office, unless you publicly announce the
contents of this report earlier, we will make no further distribution
until 10 days after the date of this letter.  At that time, we will
send copies of this report to other appropriate congressional
committees; the Administrator, EPA; the Director, Office of
Management and Budget; and other interested parties.  We will also
make copies available to others upon request. 

If you need further information, please call me at (202) 512-4907. 
Major contributors to this report are listed in appendix II. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
Protection Issues


ORGANIZATIONS CONTACTED
=========================================================== Appendix I

American Petroleum Institute
Chemical Manufacturers Association
Chemical Specialties Manufacturers Association
The Chemical Use Reporting Task Force (organized through the U.S. 
Chamber of Commerce)
Electronic Industries Association
National Conference of State Legislatures
National Governors' Association
The National Pollution Prevention Roundtable
Working Group on Community Right-to-Know


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

Charles Barchok, Jr., Assistant Director
Jacqueline M.  Garza, Evaluator-in-Charge
Richard P.  Johnson, Senior Attorney
Derek Updegraff, Senior Evaluator


SELECTED BIBLIOGRAPHY
=========================================================== Appendix 0

This bibliography provides the federal government and federally
sponsored studies, state government and state-sponsored studies, and
nongovernmental studies that we reviewed. 


   FEDERAL GOVERNMENT AND
   FEDERALLY SPONSORED STUDIES
--------------------------------------------------------- Appendix 0:1

EPA Office of Policy, Planning, and Evaluation, Pollution Prevention
and Toxics Branch.  Pollution Prevention Frontiers and Other
Approaches to Pollution Prevention Assessment.  June 1994. 

EPA Office of Pollution Prevention and Toxics.  Issues Paper. 
Expansion of the Toxics Release Inventory to Gather Chemical Use
Information:  TRI Phase III:  Use Expansion, Sept.  2, 1994. 

EPA Office of Pollution Prevention and Toxics.  Issues Paper No.  2,
Expansion of the Toxics Release Inventory to Gather Chemical Use
Information:  TRI Phase III, Oct.  4, 1995. 

EPA Office of Pollution Prevention and Toxics.  Issues Paper No.  3,
TRI Phase III:  Expansion of the EPA Community Right-to-Know Program
to Increase the Information Available to the Public on Chemical Use,
Sept.  18, 1996. 

The National Academy of Sciences.  Tracking Toxic Substances at the
Industrial Facilities:  Engineering Mass Balance Versus Materials
Accounting.  Washington, D.C.:  National Academy Press, 1990. 


   STATE AND STATE-SPONSORED
   STUDIES
--------------------------------------------------------- Appendix 0:2

Aucott, Michael, et al.  Industrial Pollution Prevention Trends in
New Jersey.  New Jersey Department of Environmental Protection, Dec. 
1996. 

Dierks, Angie, et al.  New Jersey's Planning Process:  Shaping a New
Vision of Pollution Prevention.  Tellus Institute for Resource and
Environmental Strategies.  Study prepared for the New Jersey
Department of Environmental Protection, Office of Pollution
Prevention, June 1996. 

Geiser, Kenneth.  Regulatory Reform Towards an Alternative
Environmental Protection System.  Toxics Use Reduction Institute,
University of Massachusetts, June 1996. 

Geiser, Kenneth.  Tracking Pollution Prevention Progress in
Massachusetts.  Toxics Use Reduction Institute, University of
Massachusetts, Dec.  1995. 

Geiser, Kenneth.  Tracking Pollution Prevention Progress in
Massachusetts:  Part Two.  Toxics Use Reduction Institute, University
of Massachusetts, Oct.  1996. 

Harriman, Elizabeth, and Maureen Hart.  Measuring Progress in Toxics
Use Reduction and Pollution Prevention.  Toxics Use Reduction
Institute, University of Massachusetts, Technical Report No.  30,
1996. 

Minnesota Office of Waste Management.  Toxic Chemical Use Report. 
Jan.  1993. 

Massachusetts Department of Environmental Protection.  Progress
Toward the Byproduct Reduction Goal of the Toxics Use Reduction Act,
1995 Executive Report. 

New Jersey Department of Environmental Protection and Energy, Office
of Pollution Prevention.  Materials Accounting As A Potential
Supplement to the Toxics Release Inventory for Pollution Prevention
Measurement Purposes:  A Case Study Analysis of New Jersey Throughput
and TRI Data.  Dec.  1993. 


   STUDIES BY NONGOVERNMENTAL
   ORGANIZATIONS
--------------------------------------------------------- Appendix 0:3

Burns, Paul, and Hillel Gray.  Tracking the Toxics Crisis:  A Call
for State Action on Toxics Use Reduction.  Massachusetts Public
Interest Research Group and The National Environmental Law Center. 
Jan.  1994. 

Chemical Manufacturers Association and SRI International.  Analysis
of Impact of U.S.  Federal and State Reporting Requirements on
Sensitive and Proprietary Company Information.  1994. 

Geiser, Ken, and Frances H.  Irwin, ed.  Rethinking the Materials We
Use:  A New Focus for Pollution Policy.  World Wildlife Fund.  1993. 

Hearne, Shelly A., and Michael Aucott.  "Source Reduction Versus
Release Reduction:  Why the TRI Cannot Measure Pollution Prevention,"
Pollution Prevention Review Winter 1991-92. 

Hearne, Shelly A.  "Tracking Toxics:  Chemical Use and the Public's
`Right-to-Know'" Environment.  Vol.  38, No.  6, July/August 1996. 

INFORM.  A Clearer View of Toxics:  New Jersey's Reporting
Requirements As a Model for the United States.  1994. 

INFORM.  Toxics Watch 1995. 

Kline and Company, Inc.  for the Chemical Manufacturers Association. 
Impact of Proposed TRI-Phase 3 Reporting Requirements on Intellectual
Property Protection, Nov.  1995. 

Natan, Thomas E.  Jr., et al.  Evaluation of the Effectiveness of
Pollution Prevention Planning in New Jersey:  A Program-Based
Evaluation.  Hampshire Research Associates, Inc.  May 1996. 


*** End of document. ***