Environmental Information: EPA Could Better Address Concerns About
Disseminating Sensitive Business Information (Chapter Report, 06/25/1999,
GAO/RCED-99-156).

Since the mid-1980s, the federal government and several states have
introduced public "right-to-know" initiatives on environmental issues.
These initiatives require industries to report on their use and
discharge of potentially harmful substances and require government
agencies to make this information available to the public. Companies,
however, have questioned the appropriateness of publicly disclosing
increasingly detailed facility-level information. Specifically, they are
concerned that their submissions contain "sensitive business
information" that, if released, could harm their competitiveness. This
concern is heightened because companies around the world are
increasingly hiring "competitive intelligence" professionals to collect
and analyze legally obtained information to glean insight into their
competitors' operations. This report (1) provides information on the
usefulness of publicly available information to competitive intelligence
professionals and (2) assesses EPA's efforts to address industry
concerns about providing the public with access to sensitive business
information.

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

 REPORTNUM:  RCED-99-156
     TITLE:  Environmental Information: EPA Could Better Address
	     Concerns About Disseminating Sensitive Business
	     Information
      DATE:  06/25/1999
   SUBJECT:  Reporting requirements
	     Environmental impact statements
	     Government information dissemination
	     Proprietary data
	     Economic espionage
	     Competition
	     Freedom of information
IDENTIFIER:  EPA Toxic Release Inventory

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    United States General Accounting Office GAO                Report
    to the Chairman and Ranking Minority Member, Subcommittee on VA,
    HUD, and Independent Agencies, Committee on Appropriations, U. S.
    Senate June 1999          ENVIRONMENTAL INFORMATION EPA Could
    Better Address Concerns About Disseminating Sensitive Business
    Information GAO/RCED-99-156 GAO United States General Accounting
    Office Washington, D.C. 20548 Resources, Community, and Economic
    Development Division B-281230 June 25, 1999 The Honorable
    Christopher S. Bond Chairman The Honorable Barbara Mikulski
    Ranking Minority Member Subcommittee on VA, HUD, and Independent
    Agencies Committee on Appropriations United States Senate This
    report discusses the usefulness of information reported to
    environmental regulatory agencies in "competitive intelligence"
    practices-the collection and analysis of legally obtained
    information to gain insights into competitors' operations. The
    report also assesses the Environmental Protection Agency's efforts
    to address industries' concerns about providing the public access
    to sensitive business information. We are sending copies of this
    report to other Senate and House committees and subcommittees with
    jurisdiction over environmental, commerce and business, and
    information management issues. We will make copies available to
    others upon request. If you or your staff have any questions,
    please call me on (202) 512-6111. Major contributors to this
    report are listed in appendix I. David G. Wood Associate Director,
    Environmental Protection Issues Executive Summary Purpose
    Since the mid-1980s, the federal government and several states
    have implemented various environmental public "right-to-know"
    initiatives. These initiatives require industries to report on
    their use and discharge of potentially harmful substances and
    require government agencies to make this information available to
    the public. Although the Environmental Protection Agency (EPA)
    asserts that right-to-know information has resulted in significant
    benefits to public health and the environment, the industries
    required to submit this information have questioned the
    appropriateness of reporting and publicly disclosing increasingly
    detailed facility-level information. Specifically, representatives
    of various industries have expressed concerns that their
    submissions contain "sensitive business information" that, if
    released, would harm their competitiveness. This concern is
    heightened because companies around the world have increasingly
    employed "competitive intelligence" professionals who collect and
    analyze legally obtained information to glean insights into the
    operations of their employers' competitors. In light of this
    concern, the Senate report accompanying the Veterans'
    Administration, Housing and Urban Development, and Independent
    Agencies' fiscal year 1998 appropriations bill and subsequent
    discussions with Appropriations Committee staff directed GAO to
    (1) provide information on the usefulness of publicly available
    environmental information to competitive intelligence
    professionals and (2) assess EPA's efforts to address industries'
    concerns about providing the public with access to sensitive
    business information. Background    EPA and the states collect
    information from industrial facilities to monitor compliance with
    environmental laws and regulations, to measure the progress made
    towards reducing pollution, and to provide information to the
    public about hazardous materials in their communities. Over the
    past decade, the Congress, the executive branch, and several
    states have made this and other environmental information more
    available to the public. In 1986, the Congress enacted the
    Emergency Planning and Community Right-to-Know Act, which requires
    industries to report to EPA information on toxic chemicals present
    at and released from their facilities and requires EPA to make
    this information publicly available. EPA has been considering
    implementing additional initiatives to collect and disseminate
    information. Under one of the more controversial of these, EPA is
    considering requiring industries to report the amounts of toxic
    chemicals entering a facility, transformed into products and
    waste, and leaving the facility. A similar reporting requirement
    has been in place in New Jersey and Massachusetts for several
    years. Both the state and the proposed EPA programs are commonly
    referred to as "materials accounting." Page 2
    GAO/RCED-99-156 Sensitive Business Information Executive Summary
    Due, in part, to the large volume of negative comments EPA
    received in 1996 on its advance notice of proposed rulemaking on
    materials accounting, the agency has delayed further regulatory
    efforts and has no immediate plans to implement such a program.
    Among other things, industries have raised concerns that materials
    accounting reporting would reveal sensitive information about
    their business operations that could be used by others to gain an
    unfair competitive advantage. These concerns were most prevalent
    in the chemical manufacturing sector. Under the Freedom of
    Information Act, federal agencies generally must make their
    records (including material obtained by an agency) available to
    the public upon request. This requirement does not apply to, among
    other things, records constituting trade secrets or confidential
    business information. EPA has established general procedures for
    considering claims of confidentiality under the act, as well as
    procedures for each of its relevant programs to take into account
    any specific information disclosure or protection provisions in
    the program's authorizing statute. Certain program regulations
    also contain provisions governing the disclosure of data. Results
    in Brief    Competitive intelligence professionals, industry
    representatives, and environmental officials expressed a range of
    views on the usefulness of publicly available environmental
    information provided by businesses. For example, industry
    representatives told GAO that environmental information reported
    by businesses-such as air and water permits or materials
    accounting information-often contains valuable details about their
    operations. In contrast, most intelligence professionals said
    that, while such information is useful for some of their purposes,
    it is rarely sufficient for reliable analyses when used alone. New
    Jersey and Massachusetts environmental officials also questioned
    the value of this information for competitive intelligence
    purposes and noted that businesses made very few claims of
    confidentiality in their states when submitting even the
    controversial materials accounting information. Despite the wide
    range of views on the value of environmental information for
    competitive intelligence purposes, competitive intelligence
    professionals generally agreed that multiple types and sources of
    information are needed to develop comprehensive and reliable
    analyses of competitors' business operations. Industry officials
    also acknowledged that they could do a better job of protecting
    their sensitive business information while still complying with
    reporting requirements. Page 3
    GAO/RCED-99-156 Sensitive Business Information Executive Summary
    EPA has made a number of efforts to address industries' concerns
    about the collection and the dissemination of sensitive business
    information. For example, during EPA's recent consideration of
    materials accounting reporting, the agency made several attempts
    to better understand and address industries' concerns. However,
    many of the industry officials that GAO contacted continue to have
    concerns about EPA's lack of consistent policies and practices for
    collecting and disseminating sensitive business information. In
    addition, GAO, industry trade groups, and most recently EPA itself
    have raised concerns about the absence of consistent, high-level
    agency attention to information management activities. In response
    to these concerns, EPA will soon consolidate many of these
    activities in a new Information Office. However, it remains
    unclear how the new office will address issues related to
    collecting and disseminating sensitive business information. GAO
    is recommending that this new office play a central role in
    ensuring that these issues are adequately addressed. Principal
    Findings Usefulness of                  Competitive intelligence
    professionals and industry representatives Environmental
    Information      expressed a range of views on the usefulness of
    publicly available to Competitive Intelligence    environmental
    information reported by businesses. Although they Professionals
    Can Vary         generally agreed that environmental information
    provides only one piece of a "puzzle," they disagreed on the
    significance of that piece. Industry representatives-including
    some with competitive intelligence responsibilities-told GAO that
    environmental information reveals valuable details about business
    operations. These industry representatives told GAO that their
    specialized knowledge of industrial processes and technology made
    this information more valuable to them than it might be for
    intelligence professionals who are consultants and might work in a
    number of fields and have less specialized knowledge. For example,
    industry representatives said that they used details found in
    publicly available environmental documents-such as equipment
    specifications, operating rates, process descriptions, and volumes
    of raw materials-to determine competitors' production costs and
    help make their own firm's pricing strategy more competitive.
    These intelligence professionals said that information obtained
    through other sources usually lacked sufficient precision for
    similar analyses of competitors' costs. Page 4
    GAO/RCED-99-156 Sensitive Business Information Executive Summary
    In contrast, other intelligence professionals-often contractors
    who might sell their services to a number of firms in a variety of
    sectors-told GAO that while environmental information is useful
    for some of their intelligence objectives, it is rarely sufficient
    for reliable analyses of competitors' business operations.
    Furthermore, these intelligence professionals told GAO that, in
    the absence of this information, they could obtain equivalent
    information from other sources. According to these intelligence
    professionals, environmental information usually provides a
    starting point for more comprehensive research, including
    interviews with knowledgeable industry sources, such as a
    competitor's suppliers, distributors, customers, and, if possible,
    employees. Many competitive intelligence professionals emphasized
    that information obtained through interviews is more important
    than that obtained from other sources because people with direct
    knowledge of a competitor are the most reliable and current
    sources of information. This view is bolstered by a 1998 survey
    conducted by security specialists that concluded that the greatest
    risk of losing proprietary information comes from persons with a
    trusted relationship with a company, such as employees,
    consultants, and business partners.1 Some industry officials that
    GAO contacted acknowledged that they could do a better job in
    training their employees to protect sensitive business
    information. New Jersey and Massachusetts regulatory officials and
    environmental advocacy groups also questioned the usefulness of
    environmental information to intelligence professionals. These
    officials pointed out that very few firms in their states request
    confidentiality on information they submit under the states'
    materials accounting programs-even though these states rarely
    challenge these requests. In fact, fewer than 2 percent of the
    facilities in New Jersey and Massachusetts have made
    confidentiality claims on the materials accounting information
    they have reported to their states. Industry representatives
    offered several explanations for the small number of
    confidentiality claims they have made. These representatives told
    GAO that some companies lack adequate procedures for determining
    whether the information they submit contains sensitive business
    information. In other cases, the company may review submissions
    but decide not to make confidentiality claims because the size and
    the complexity of the facility effectively "mask" potentially
    sensitive information. 1ASIS Trends in Intellectual Property Loss
    Survey Report, Richard J. Heffernan and Dan Swartwood, and the
    American Society for Industrial Security Safeguarding Proprietary
    Information Standing Committee, 1998. Page 5
    GAO/RCED-99-156 Sensitive Business Information Executive Summary
    EPA Could Improve Its    Despite its efforts to address
    industries' concerns about the collection and Efforts to Address
    the dissemination of sensitive business information, EPA could do
    a better Industries' Concerns     job in addressing these long-
    standing issues. To its credit, the agency has expanded its
    outreach efforts to stakeholders in the past several years. For
    example in 1997, EPA established a Toxic Data Reporting Committee
    under its National Advisory Council for Environmental Policy and
    Technology. The Committee was established to solicit stakeholders'
    input on ways to improve the reporting of data on toxic substances
    and has representatives from a cross section of industry.
    Similarly, when EPA published its advance notice of proposed
    rulemaking on materials accounting in 1996, the agency made a
    special effort to obtain industries' views on how EPA could
    address their concerns about collecting and disseminating
    sensitive business information. Nonetheless, industry
    representatives have maintained that EPA lacks consistent, high-
    level attention to their concerns about sensitive business
    information. For example, a November 1998 study prepared for the
    Chemical Manufacturers Association concluded that EPA has "a
    labyrinth of widely different policies for the protection of
    sensitive business information."2 Among other things, the report
    recommended that EPA reconsider its policy decisions and legal
    interpretations that, it claimed, have unnecessarily restricted
    the ability of its members to make claims of confidentiality. The
    report also recommended that the Congress replace various
    confidentiality provisions with a uniform statute that would
    increase industries' ability to claim confidentiality. In response
    to numerous concerns about its overall information management
    policies and procedures, in 1998, EPA's Administrator announced
    plans for the creation of a new program office for information
    policy and management. In EPA's December 1998 report on options
    for the structure and functions of the new Information Office, a
    brief reference is made to the possibility of addressing sensitive
    business information issues in the future, but the report does not
    elaborate on how, or if, the office will address them.3 EPA
    officials responsible for organizing the new Information Office
    told GAO that the office would likely address these issues and
    their relationship to broader information policy and management
    issues. However, EPA has not yet determined how it should do so.
    2Protection of Sensitive Business Information at the Environmental
    Protection Agency, Ropes & Gray, Nov. 20, 1998. 3Final Report:
    Structural and Functional Options for EPA's New Information
    Office, Comprehensive Information Management Task Force and the
    Information Working Group, EPA, Dec. 1, 1998. Page 6
    GAO/RCED-99-156 Sensitive Business Information Executive Summary
    Recommendation     To help ensure that the long-standing concerns
    about collecting and disseminating sensitive business information
    are addressed in a consistent, comprehensive manner, GAO
    recommends that the Administrator, EPA, direct the Program Manager
    of the newly established Information Office to develop an action
    plan that details how the office will address issues surrounding
    sensitive business information. A central feature of this plan
    should address how EPA will balance its need for collecting and
    disseminating potentially sensitive business information with
    industries' concerns about such activities. To help ensure that
    EPA fully considers the concerns of all interested parties, this
    action plan should be developed with extensive and representative
    involvement by stakeholders. Agency Comments    GAO provided a
    draft of this report to EPA for comment and held discussions with
    officials from the Office of Information Transition and
    Organizational Planning. The agency generally agreed with the
    information presented in the report, concurred with GAO's
    recommendation, and stated that GAO had taken a fair approach to
    discussing this challenging issue. EPA offered several technical
    comments and clarifications, which GAO incorporated throughout the
    report as appropriate. Page 7
    GAO/RCED-99-156 Sensitive Business Information Contents Executive
    Summary
    2 Chapter 1
    10 Introduction              EPA's Programs to Collect and
    Disseminate Information                          10 Industries'
    Concerns About the Disclosure of Sensitive Business
    11 Information Related GAO Products
    12 Objectives, Scope, and Methodology
    13 Chapter 2
    15 The Usefulness of         Some Competitive Intelligence
    Professionals Use Environmental                  15 Information
    Extensively Environmental             Some Competitive
    Intelligence Professionals See Little Value in                16
    Information to               Environmental Information Competitive
    Industry Could Better Protect Its Sensitive Business Information
    19 Intelligence Professionals Can Vary Chapter 3
    20 EPA Could Improve         EPA's Efforts to Address Industries'
    Concerns                                  20 EPA's Efforts Have
    Not Addressed Industries' Concerns to Their                 21 Its
    Efforts to Address       Satisfaction Industry Concerns
    EPA's New Information Office Is Positioned to Address
    23 Long-Standing Problems Conclusions
    24 Recommendation
    25 Agency Comments
    25 Appendix                  Appendix I: GAO Contacts and Staff
    Acknowledgments                             26 Figure
    Figure 2.1: The Types and the Sources of Information Used by
    17 Intelligence Professionals Abbreviations ASIS         American
    Society for Industrial Security EPA          Environmental
    Protection Agency FBI          Federal Bureau of Intelligence Page
    8                              GAO/RCED-99-156 Sensitive Business
    Information Page 9       GAO/RCED-99-156 Sensitive Business
    Information Chapter 1 Introduction Since the mid-1980s, the
    Environmental Protection Agency (EPA) has initiated a number of
    actions to make information on the sources and the levels of
    pollution widely available to the public. Although EPA allows
    submitters of information to request claims of confidentiality if
    the public release of the information would adversely affect their
    businesses, many in industry believe that EPA collects and
    disseminates too much sensitive business information. In recent
    years, these concerns have heightened with the growing use of
    "competitive intelligence" practices-the gathering and analyzing
    of legally obtained information on one's competitors to gain
    insights into their business operations- by companies around the
    globe. EPA's Programs to    Through the Freedom of Information Act
    and the information disclosure Collect and          provisions of
    environmental statutes, the public has access to much of the
    information EPA generates and collects. EPA has promulgated both
    Disseminate          agencywide and program-specific regulations
    governing the submission Information          and the disclosure
    of information. A business may request that EPA treat certain
    submitted data as confidential and withhold it from public
    disclosure, which the agency will do if it determines, among other
    things, that disclosing the information is likely to substantially
    harm the competitive position of that business. Provisions in
    environmental statutes impose program-specific restrictions on the
    types of data that may receive confidential treatment or must be
    publicly disclosed. EPA and the states collect information from
    industrial facilities to monitor compliance with environmental
    laws and regulations, to measure the progress made towards
    reducing pollution, and to provide information to the public on
    hazardous materials in their communities. For example, under the
    Clean Water Act, EPA must make certain discharge data publicly
    available. One of the most significant sources of publicly
    available environmental information is the Toxic Release
    Inventory, established under the Emergency Planning and Community
    Right-to-Know Act of 1986. Businesses must submit to EPA
    information on toxic chemicals present at, and released from,
    their facilities. The act requires EPA to make this information
    publicly available through computer telecommunications as well as
    other means and authorizes businesses to claim only specific
    chemical identities as confidential. EPA has expanded the
    inventory several times to include additional types of businesses
    and chemicals. According to EPA, since the reporting of releases
    of toxic chemicals under the Toxic Release Inventory began in
    1988, the total releases of chemicals listed on the inventory has
    been reduced nearly 43 percent. The agency has Page 10
    GAO/RCED-99-156 Sensitive Business Information Chapter 1
    Introduction considered also requiring businesses to report the
    amounts of specific toxic chemicals that enter the facility, are
    used within it, and leave either as products, by-products, or
    waste. This is referred to as "materials accounting," and EPA
    asserts that reporting and disseminating such data would provide a
    more detailed and comprehensive picture to the public about
    environmental conditions and toxic chemicals at facilities located
    near their communities. Due, in part, to the large volume of
    negative comments EPA received in 1996 when it announced its
    consideration of a nationwide materials accounting program in an
    advance notice of proposed rulemaking, the agency has delayed
    further regulatory efforts and has no immediate plans to implement
    such a program. However, Massachusetts and New Jersey currently
    require the reporting of materials accounting data. Industries'
    Concerns     Although representatives within industry acknowledge
    that there are About the Disclosure     benefits to publicly
    disseminating some of the information they submit to EPA, some
    have raised concerns that the disclosure of some of this of
    Sensitive Business    information will adversely affect their
    businesses' competitiveness. These Information
    concerns have heightened in recent years as EPA has increased the
    type and the amount of information it collects and disseminates
    and domestic and foreign competitors have increased their use of
    "competitive intelligence" methods. Some industry representatives
    maintain that domestic firms are at a competitive disadvantage
    because U.S. firms are often required to disclose more detailed
    information than their foreign counterparts.4 Competitive
    intelligence is the process of gathering and analyzing information
    on one's competitors to gain insights into their business
    operations. Unlike economic espionage, competitive intelligence
    relies on legal methods to collect data. Companies use competitive
    intelligence to answer questions about such things as their
    competitors' production costs, timelines for new product
    introductions, market share, manufacturing processes and capacity,
    and expansion plans. Competitive intelligence professionals answer
    these questions by piecing together information using multiple
    data collection methods and information sources ranging from
    literature searches to interviews with the competitors' employees.
    Although no specific information is available on the economic
    losses incurred by U.S. firms due to legal competitive
    intelligence activities, the Federal Bureau of Intelligence's
    (FBI) National Counterintelligence Center 4Because of the vast
    array of environmental reporting requirements around the world, we
    did not evaluate the accuracy of this claim. Page 11
    GAO/RCED-99-156 Sensitive Business Information Chapter 1
    Introduction reported that U.S. firms may have lost over $250
    billion in 1996 through those activities and illegal espionage
    practices.5 The Chemical Manufacturers Association has been
    especially critical of EPA's information collection and
    dissemination programs and has sponsored several studies that
    examined the link between the disclosure of sensitive business
    information and the environmental reporting requirements.6 The
    Association maintains that EPA's policy decisions and legal
    interpretations unnecessarily limit industries' ability to claim
    information as confidential. Many industry officials have
    expressed strong objections to EPA's materials accounting
    proposal, in part because much of the information (e.g., raw
    material stocks and usage rates) that might be reported under such
    a program would make it very easy for competitors to gain
    important knowledge about their business operations. These
    concerns are particularly strong within the chemical-manufacturing
    sector. Related GAO Products In recent years, GAO has issued
    several reports on EPA's information collection, dissemination,
    and management activities. In a 1998 report on EPA's information
    collection and dissemination activities, we concluded that
    although EPA had projects underway to help address information
    gaps related to facilities' toxic chemical releases, the agency
    had not developed policies, procedures, and standards to govern
    various aspects of its public dissemination efforts.7 To help
    ensure that EPA provides the public with information that is
    accurate, complete, and relevant, we recommended that it expand
    its guidance on information resources management by developing
    agencywide policies and procedures for program offices involved in
    designing, developing, and implementing information dissemination
    projects. Such guidance and standards should address obtaining
    stakeholders' input in the projects' design and development,
    testing to correct data errors, and communicating contextual
    information on the data's uses and limitations. EPA agreed with
    our recommendation. 5The Center relied on statistics derived from
    a survey conducted by the American Society of Industrial Security,
    a trade association that represents professionals in the field of
    corporate security. 6The Association represents the chemical
    industry on legislative, regulatory, and legal matters at the
    international, national, and state levels. 7Environmental
    Information: Agencywide Policies and Procedures Are Needed for
    EPA's Information Dissemination (GAO/RCED-98-245, Sept. 24, 1998).
    Page 12                                          GAO/RCED-99-156
    Sensitive Business Information Chapter 1 Introduction In 1997, we
    reported on the status of federal and state efforts to require
    industries' reporting of detailed materials accounting
    information.8 The report summarized various studies on materials
    accounting programs in New Jersey and Massachusetts and on
    stakeholders' views on the implications of a potential federal
    program. Several studies focused on the benefits associated with
    materials accounting programs while others emphasized their
    drawbacks-including the potential that disclosure of reported
    information could reveal industrial trade secrets. Objectives,
    Scope,    This report responds to the Senate report accompanying
    the VA, HUD, and and Methodology       independent agencies'
    fiscal year 1998 appropriations bill and subsequent discussions
    with Appropriations Committee staff. We were asked by Committee
    staff to (1) provide information on the usefulness of publicly
    available environmental information to competitive intelligence
    professionals and (2) assess EPA's efforts to address industries'
    concerns about providing the public access to sensitive business
    information. To determine how competitive intelligence
    professionals use information provided by EPA and the states, we
    interviewed individuals at 13 firms. Some of these individuals
    were consultants who performed competitive intelligence on a full-
    time basis while others were industry employees who did this work
    as part of their job. We selected individuals and firms based on
    their experience in preparing analyses on the chemical-
    manufacturing sector. The individuals and firms were judgmentally
    selected to reflect a range of views. The selected sample is not
    necessarily representative nor can the views we obtained be
    projected to the universe of competitive intelligence
    professionals. To ensure that our sample contained a wide range of
    views and appropriate experience, we asked the Society of
    Competitive Intelligence Professionals and industry trade groups,
    such as the Chemical Manufacturers Association, to recommend
    competitive intelligence professionals and firms that met our
    criteria.9 In addition to interviewing competitive intelligence
    professionals, we reviewed journal articles and studies on
    competitive intelligence and attended competitive intelligence
    training workshops. Because industries have particular concerns
    about EPA's consideration of a materials accounting program, we
    interviewed state environmental and industry officials in
    Massachusetts and New Jersey to obtain their perspectives on
    sensitive business 8Toxic Substances: Few States Have Considered
    Reporting Requirements for Chemical Use Data (GAO/RCED-97-154,
    June 6, 1997). 9The Society is an organization of individual
    competitive intelligence professionals from around the world. Page
    13                                        GAO/RCED-99-156
    Sensitive Business Information Chapter 1 Introduction information
    matters related to their states' materials accounting programs.
    The firms contacted in these states were judgmentally selected,
    and the views we obtained are not necessarily representative. We
    selected the firms from a larger universe of those that have
    historically made claims of confidentiality and from
    recommendations from industry and environmental groups at the
    national and state levels. Our work focused solely on the
    information collection and analysis methods of legal competitive
    intelligence rather than on economic espionage or illegal uses of
    such information, such as by terrorist groups. We also interviewed
    officials in the FBI's National Security Division and the American
    Society for Industrial Security to obtain their perspectives on
    the potential losses of U.S. businesses due to competitive
    intelligence activities and the steps that companies can take to
    better protect their sensitive business information. To assess
    EPA's efforts to address industries' concerns about the
    implications of providing public access to sensitive business
    information, we interviewed EPA officials involved in information
    collection and dissemination policies, company and trade
    association representatives from industries that submit
    information to EPA, and representatives of national environmental
    and public interest groups. We also reviewed relevant statutes and
    EPA's policies and procedures on collecting, protecting, and
    disseminating industry information and for obtaining stakeholders'
    input. EPA commented on a draft of this report, and, where
    appropriate, we incorporated its comments in the final report. Our
    review was conducted from June 1998 through April 1999 in
    accordance with generally accepted government auditing standards.
    Page 14                            GAO/RCED-99-156 Sensitive
    Business Information Chapter 2 The Usefulness of Environmental
    Information to Competitive Intelligence Professionals Can Vary The
    competitive intelligence professionals and industry
    representatives that we contacted expressed a range of views on
    the usefulness of publicly available information businesses report
    to environmental agencies. Most of the competitive intelligence
    professionals and industry representatives agreed on the basic
    framework for how competitive intelligence is conducted. In
    particular, they described competitive intelligence as a jigsaw
    puzzle or mosaic because their analyses are pieced together from
    numerous types of information gathered and selected from a wide
    array of sources. Although they generally agreed that information
    obtained from environmental agencies provides only one piece of
    the "puzzle," they disagreed on the significance of that piece.
    Industry representatives-including some with competitive
    intelligence responsibilities-stated that the information reported
    by businesses often contains valuable details about their
    competitors while other competitive intelligence professionals
    said that such information is neither sufficient or even necessary
    for their analyses. Because examples were provided to us that
    supported a range of views, it is apparent that the value of this
    information for competitive intelligence purposes varies from case
    to case. Regardless of their views on the usefulness of this
    information, industry officials acknowledged that they could do a
    better job in protecting their sensitive business information
    while still complying with EPA's and states' reporting
    requirements. Some Competitive     Industry representatives-
    including some with competitive intelligence Intelligence
    responsibilities-told us that they use information reported to
    environmental agencies to uncover valuable details about their
    Professionals Use    competitors. Although they acknowledged that
    this information may not Environmental        be useful for
    gaining insights into operations at some facilities, these
    industry representatives said that the information reported to
    Information          environmental agencies is among the most
    valuable type of information Extensively          available to
    them and that their work is becoming easier as more of this
    information is publicly disseminated. Accordingly, they carefully
    review their competitors' environmental records, such as air and
    water permits and, in Massachusetts and New Jersey, materials
    accounting data. They said that these records disclose such useful
    pieces of information as equipment specifications, operating
    rates, process descriptions, amounts of raw materials, and other
    details. The industry representatives who emphasized the
    importance of environmental information often cited materials
    accounting data as among the most valuable type of such
    information. They said that the details Page 15
    GAO/RCED-99-156 Sensitive Business Information Chapter 2 The
    Usefulness of Environmental Information to Competitive
    Intelligence Professionals Can Vary found in materials accounting
    data are not available from other environmental documents. They
    told us that data on the quantity of chemicals used and processed
    at a facility can reveal precise information about a competitor's
    production levels, operational efficiencies, and production costs.
    They frequently mentioned that the identity and the efficiency of
    catalysts-ingredients used to control reactions in chemical
    manufacturing processes-is information found only in materials
    accounting data. Representatives of the chemical manufacturing
    industry also told us that the precision of materials accounting
    data enables them to make reliable estimates of competitors'
    production costs, the primary basis of competition in their
    markets, and that these estimates are used to develop more
    effective pricing and marketing strategies. These intelligence
    professionals said that information obtained through other sources
    usually lacked sufficient precision for similar analyses of
    competitors' costs. Industry representatives who perform
    competitive profiling for their firms described themselves as
    experts with specialized knowledge of chemical processes and
    technology. They said that this expertise makes environmental
    information more valuable to them than it would be to intelligence
    professionals who work in a number of fields and have less in-
    depth knowledge in any one field. One intelligence professional
    told us that his specialized knowledge of chemical manufacturing
    technology enables him to pick out process-specific insights from
    a facility's environmental documents even when that information is
    combined with information about other unrelated processes. Some
    Competitive     In contrast, other competitive intelligence
    professionals we spoke to said Intelligence         that they use
    environmental information for some of their analyses but generally
    rely on a much broader range of information sources. In
    Professionals See    addition, these intelligence professionals
    said that when they do use Little Value in      environmental
    information, they regard it as a starting point for more
    comprehensive research. For example, a representative of an
    intelligence Environmental        consulting firm told us that
    only once in his experience did he obtain an Information
    answer to a research question simply by conducting a search of
    environmental information. More commonly, these firms collect as
    much environmental and other information on targeted businesses as
    possible and then sift through the records for useful pieces of
    information that might suggest further areas of more in-depth
    research. For example, an environmental permit could contain the
    name and telephone number of a plant manager who could then be
    contacted for additional information. Page 16
    GAO/RCED-99-156 Sensitive Business Information Chapter 2 The
    Usefulness of Environmental Information to Competitive
    Intelligence Professionals Can Vary Figure 2.1 shows how different
    types and sources of information are combined to glean insights on
    competitors' business operations. Figure 2.1: The Types and the
    Sources of Information Used by Intelligence Professionals
    Publications
    Industry experts Help wanted ads               Directories
    Trade associations        Researchers Periodicals
    Trade literature
    Stock analysts            Consultants Newspapers Competitive
    Analysis Government filings Securities and                 Food
    and Drug
    Company associates Exchange Commission            Administration
    Suppliers           Unions Environmental Protection       Court
    cases
    Distributors        Other competitors Agency
    Uniform Commercial
    Customers Occupational Safety            Code and Health
    Administration                                          The
    competitor Press releases            Interviews with In-house
    newsletters      company employees Trade shows
    Speeches Web sites Some of the intelligence professionals we spoke
    to said that materials accounting data may contain useful
    information but that the information contained in environmental
    documents can generally be obtained through other sources. For
    this reason, one intelligence professional told us that profiling
    is no easier in the two states that require materials accounting
    than it is in states without such programs. A report prepared for
    the Chemical Manufacturers Association-often cited by industry as
    evidence that materials accounting programs threaten their
    competitiveness-acknowledges that an initial analysis using
    materials Page 17                                    GAO/RCED-99-
    156 Sensitive Business Information Chapter 2 The Usefulness of
    Environmental Information to Competitive Intelligence
    Professionals Can Vary accounting information in combination with
    other publicly available environmental information "does not
    constitute a high-confidence, decision-grade profile." Instead,
    the report concludes that such an analysis provides "a highly
    useful core of understanding around which an interested outside
    party can build a more comprehensive investigation." When we spoke
    with the authors of the report, they confirmed that materials
    accounting data does not substantially affect the ease of their
    work. Many competitive intelligence professionals said that their
    most important information comes from personal contacts rather
    than from publicly available environmental information. They use
    interviews to confirm and expand on information obtained from
    publicly available environmental records and other sources. They
    said that people with direct knowledge of a competitor-such as the
    competitor's suppliers, distributors, customers, and employees-are
    the most reliable and current sources of information.
    Professionals with competitive intelligence consulting firms told
    us that they frequently call these sources to gather information
    and commented that company employees and business partners often
    are eager to talk about their work to someone who shows interest.
    The competitive intelligence professionals who said that
    environmental information is not a critical source for competitive
    profiling tended to work as consultants for, rather than employees
    within, companies. Environmental officials in New Jersey and
    Massachusetts and environmental advocacy groups who agreed with
    this view pointed to the small number of claims of confidentiality
    that had been made in these states on materials accounting data-
    even though the states rarely challenge these claims-as evidence
    that environmental information is not as sensitive as claimed by
    some in industry. In fact, fewer than two percent of the
    facilities in New Jersey and Massachusetts made confidentiality
    claims in 1996.10 According to state environmental officials,
    these numbers have varied very little from year to year. Industry
    representatives from New Jersey and Massachusetts offered several
    explanations for the small number of confidentiality claims made
    on materials accounting data and said that this does not
    necessarily indicate that the information is not useful for
    competitive profiling. For example, some companies decide not to
    make confidentiality claims 10In their comments on a draft of this
    report, EPA officials speculated that state restrictions on
    claiming confidentiality on information that can readily be
    obtained from other sources-such as reverse engineering or
    chemical analyses of waste streams-may have been a contributing
    factor to the small number of claims of confidentiality. Page 18
    GAO/RCED-99-156 Sensitive Business Information Chapter 2 The
    Usefulness of Environmental Information to Competitive
    Intelligence Professionals Can Vary because the size and the
    complexity of their facilities make it difficult for competitors
    to glean important insights from reported information. In
    addition, some representatives said that facilities in New Jersey
    and Massachusetts are not representative of facilities nationwide
    in terms of the sensitivity of their materials accounting
    information. Industry Could Better    Nonetheless, some industry
    representatives also acknowledged that Protect Its Sensitive
    companies often fail to make confidentiality claims and/or take
    other information security measures because many of the firms'
    employees Business Information     responsible for submitting
    information lack awareness of how environmental information can be
    used for competitive profiling. As a result, some sensitive
    business information could be submitted without attendant claims
    of confidentiality. In addition, some employees report more
    detailed information than required by environmental regulatory
    agencies. For example, instead of submitting simple box diagrams
    of their firm's processes, employees, who are unaware of the
    sensitivity of the information, might submit detailed schematics
    of the facility. This lack of awareness is not limited to
    submitting environmental information to regulatory agencies. For
    example, industry representatives acknowledged that they do not
    always train their employees to safeguard sensitive information
    when dealing with competitors at trade shows or responding to
    "cold" inquiries over the telephone. In fact, a 1998 survey of
    U.S. companies conducted by the American Society for Industrial
    Security (ASIS) concluded that the greatest risk to proprietary
    information comes from employees and other persons with a trusted
    relationship with a company, such as consultants and business
    partners.11 Representatives of the Society told us that employees
    often unknowingly reveal sensitive information over the telephone
    to competitive intelligence professionals. Some industry
    representatives said that their companies have taken steps to
    educate their employees on ways to better safeguard sensitive
    business information. For example, some firms train employees to
    report only the minimum amount and type of information required by
    environmental regulatory agencies. Because competitors are not
    always as careful about protecting sensitive business information,
    one representative acknowledged that environmental reporting
    requirements could work to his company's advantage. If safeguards
    are in place, they can minimize risks to a company's
    competitiveness while providing insights into the business
    operations of a less careful competitor. 11ASIS Trends in
    Intellectual Property Loss Survey Report. Page 19
    GAO/RCED-99-156 Sensitive Business Information Chapter 3 EPA Could
    Improve Its Efforts to Address Industry Concerns Although EPA has
    made several efforts to address industry's concerns about the
    collection and the dissemination of potentially sensitive business
    data, many of the industry representatives we spoke with believe
    that these efforts have been inadequate. They believe that EPA's
    interpretation of certain statutes has been inconsistent and tends
    to overemphasize the collection and the dissemination of
    information while underemphasizing the provisions to protect
    sensitive business data. In response to the number and variety of
    information management problems that have been raised by GAO and
    others, EPA recently announced plans for establishing a new
    Information Office. While EPA acknowledges that this office would
    be well-suited to address, among other things, the long-standing
    concerns about the collection and the dissemination of sensitive
    business information, the agency has not yet determined how to do
    so. EPA's Efforts to       EPA has a number of initiatives
    underway to help solicit and address Address Industries'
    industries' and other stakeholders' concerns about the collection
    and the dissemination of information. Some of these initiatives
    are Concerns               program-specific while others cut
    across program lines. The initiatives range from formal federal
    advisory councils to more informal "open-door" meetings. Although
    the issue of sensitive business information is relevant to, and
    has been raised in, several of these outreach efforts, EPA has not
    yet established a forum specifically to address this issue.
    Examples of formal advisory forums that EPA uses to solicit
    industry views include several committees within the National
    Advisory Council for Environmental Policy and Technology. The
    Council was founded in 1988 to provide a forum for public counsel
    and advice to EPA's Administrator by taking advantage of the
    respective knowledge and insights of business and industry,
    government, academia, labor, environmental advocacy organizations,
    community groups, and others involved in environmental management.
    The Council has had a number of committees that have addressed
    program-specific or agencywide information management issues. For
    example, in 1997, the Council established the Toxics Data
    Reporting Committee to address information-reporting issues
    related to EPA's Toxic Release Inventory. These issues have ranged
    from fairly narrow topics, such as revising reporting forms, to
    broader ones, such as ways for EPA to improve its presentation of
    inventory data to the public. In 1996, the Council established the
    Information Impacts Committee to provide advice and
    recommendations on EPA's current and proposed Page 20
    GAO/RCED-99-156 Sensitive Business Information Chapter 3 EPA Could
    Improve Its Efforts to Address Industry Concerns processes for
    managing its information resources. In 1998, this Committee was
    reorganized and renamed the Environmental Information and Public
    Access Committee, and it will continue to provide advice on EPA's
    information management initiatives. EPA has several other formal
    and informal mechanisms to solicit industries' input on its
    information collection and dissemination initiatives. For example,
    when the agency first announced that it was considering
    establishing a nationwide materials accounting program, it
    presented its plans in an advance notice of proposed rulemaking
    wherein, among other things, EPA invited comment on six questions
    that specifically addressed concerns about confidential business
    information. For example, EPA asked which of the proposed data
    elements were of greatest concern and how the proposed initiative
    could be modified to address these concerns while still preserving
    public access to relevant data on chemical use. EPA also asked
    whether there were any cases in New Jersey or Massachusetts where
    public access to materials accounting data had adversely affected
    businesses. In addition to the advance notice's request for public
    input, EPA held numerous public meetings and published a series of
    issue papers that sought industries' participation in crafting a
    materials accounting program that would address their concerns.
    Finally, EPA and several industry officials told us that they meet
    periodically to discuss their continuing concerns about the
    collection and the dissemination of sensitive business
    information. EPA's Efforts Have       Despite its outreach
    efforts, EPA has not fully addressed many of Not Addressed
    industries' long-standing concerns about collecting and
    disseminating sensitive business information. A common theme among
    those critical of Industries' Concerns     the agency's efforts is
    that EPA conducts its increasingly important, to Their
    Satisfaction    complex, and controversial information management
    activities in an inconsistent manner that lacks adequate attention
    from senior-level managers. For example, a 1998 report prepared
    for the Chemical Manufacturers Association concluded that EPA has
    "a labyrinth of widely different policies for the protection of
    sensitive business information" that "frustrate confidentiality
    claims for information that can be of high value for competitive
    intelligence."12 Because the Association acknowledges that at
    least some of this inconsistency results from different statutory
    12Protection of Sensitive Business Information at the
    Environmental Protection Agency, Ropes & Gray, Nov. 20, 1998. Page
    21                                       GAO/RCED-99-156 Sensitive
    Business Information Chapter 3 EPA Could Improve Its Efforts to
    Address Industry Concerns requirements concerning the collection,
    the protection, and the dissemination of business information, it
    favors a uniform statute that would make it easier for its members
    to assert confidentiality claims based on the "mosaic" argument.
    However, the Association maintains that much of this inconsistency
    results from EPA's policy decisions and legal interpretations that
    unnecessarily limit industry's ability to claim data as
    confidential. For example, the Association maintains that such
    terms as emissions data and effluent data "have been stretched by
    EPA's interpretation to include a wide range of industrial process
    information that exceeds the normal meaning of these terms."
    Furthermore, an overlybroad interpretation by one EPA office
    adversely affects industry's ability to make claims of
    confidentiality, even in other offices with a narrower
    interpretation, because, once information has been disseminated,
    it can no longer be claimed as confidential. Accordingly, the
    Association recommends that EPA engage in a broad-based,
    heightened level of scrutiny of its policies on public disclosure
    and confidentiality. Representatives from other industries also
    expressed dissatisfaction with EPA's responsiveness to their
    concerns about the collection and the dissemination of sensitive
    business information. For example, officials from the Chemical
    Specialties Manufacturers Association told us that EPA's Office of
    Prevention, Pesticides, and Toxic Substances is increasingly
    pushing a "right-to-know" agenda and is making it increasingly
    difficult to justify claims of confidentiality.13 These officials
    said that when they raised a number of substantive concerns about
    a proposal they believed would result in increased disclosure of
    sensitive business information, EPA only responded to minor
    technical issues raised by the Association and ignored their more
    substantive concerns. An official from the American Petroleum
    Institute told us that EPA is generally not very responsive to
    their concerns and declined to include them as participants in the
    advisory Toxic Data Reporting Committee even though the petroleum
    industry has unique concerns that would not be raised by other
    industries' representatives. When we asked the representatives of
    various industries if their concerns about the collection and the
    dissemination of sensitive business information could be addressed
    through administrative and/or legislative remedies, some
    respondents indicated they were generally satisfied with 13The
    Association represents companies engaged in the manufacture, the
    formulation, the distribution, and the sale of chemical specialty
    products for household, institutional, and industrial use. Page 22
    GAO/RCED-99-156 Sensitive Business Information Chapter 3 EPA Could
    Improve Its Efforts to Address Industry Concerns the existing
    provisions of EPA and the states concerning confidential business
    information provisions. Others recommended a few minor revisions,
    such as reporting information in ranges rather than in precise
    numbers. However, a few officials acknowledged that even though
    they believed such remedies could address their concerns, they did
    not want to inform EPA about them for fear that this information
    would only make it more likely that the agency would pursue a
    materials accounting program. Regardless of their views on the
    adequacy of these provisions, nearly all industry officials we
    spoke to questioned the benefits of, and remained opposed to, a
    materials accounting program. Accordingly, many believed that if
    such a program were to even slightly increase the possibility of
    releasing sensitive business information to their competitors,
    this risk would be unacceptable. EPA's New                Similar,
    and broader, concerns about EPA's inconsistent management of
    Information Office Is    information have also been raised by us
    and others in the past. In September 1998, we reported that
    industry believed that individual EPA Positioned to Address
    offices were given too much authority in making decisions about
    Long-Standing            information dissemination projects and
    had not adequately collaborated with them to identify and resolve
    concerns prior to disseminating the Problems
    information. We also found that, while EPA had a general policy
    statement on public access to its information, the agency lacked
    specific procedures and standards to help ensure that its
    dissemination activities were carried out in accordance with that
    statement. Accordingly, we recommended that EPA develop agencywide
    procedures and standards that would, among other things, address
    stakeholders' involvement in the design and the development of
    projects in the various program offices. EPA's National Advisory
    Council for Environmental Policy and Technology raised similar
    concerns and made several recommendations to the Administrator on
    ways to address some of the agency's long-standing information
    management problems. In a January 1998 report, the Council
    concluded that EPA did not provide sufficient senior-level
    management attention to information management issues and did not
    have an ongoing, formal forum to involve stakeholders.
    Accordingly, the Council recommended that EPA establish (1) a new
    organization with the appropriate authority and sole
    responsibility for managing agency information and (2) an on-
    going, broad-based information "Users' Group" to provide regular
    constructive advice, feedback from stakeholders' constituencies,
    and reactions to proposed actions and initiatives. Page 23
    GAO/RCED-99-156 Sensitive Business Information Chapter 3 EPA Could
    Improve Its Efforts to Address Industry Concerns In response to
    the number of concerns raised within and outside EPA about its
    information management, on August 11, 1998, the Administrator
    announced an initiative to "redesign our internal management
    structure to better meet the information integration needs of the
    21st century."14 To begin this process, EPA established a senior-
    level task force to develop options on how to "fundamentally
    realign information management and policy at EPA." The task force
    was instructed that these options must include a single, senior
    official in charge of information management and policy. The task
    force was also instructed to develop a plan for involving both
    internal and external stakeholders. As envisioned in the December
    1998 final report by the task force, the new Information Office's
    program manager will be vested with strong authority to help
    ensure the office's goals are attainable.15 These authorities
    would include policy setting, supported by a small policy staff.
    The new office will also have an external liaison staff to serve
    as a first point of contact "for persons and organizations that
    have a problem, issue, or need with EPA's data and information
    services and programs." The final report also noted that, while
    not a preeminent concern, industry representatives continued to
    have concerns about protecting sensitive business information.
    However, the report only listed this issue as "one to be
    considered for future phasing in." After considering the task
    force's recommendations, on December 9, 1998, the Administrator
    announced her decision regarding the structural framework for the
    new office. As recommended by the task force, the office will be
    lead by a senior-level manager and will, among other things, have
    responsibility for policy and for liaison with stakeholders. No
    mention was made of the issue of the collection and the
    dissemination of sensitive business information. In our
    discussions with EPA officials responsible for organizing the new
    office, we were told that while sensitive business information
    issues would likely be addressed in the context of broader
    information policy and management issues, EPA has not decided
    precisely how the office should do so. Conclusions    Recently,
    EPA has made a number of efforts to solicit stakeholders'
    involvement in identifying information management concerns and has
    undertaken a number of initiatives to address some long-standing
    14Memorandum on "Comprehensive Information Management," EPA's
    Administrator and Deputy Administrator, Aug. 11, 1998. 15Final
    Report: Structural and Functinal Options for EPA's New Information
    Office, Comprehensive Information Management Task Force and the
    Information Working Group, EPA, Dec. 1, 1998. Page 24
    GAO/RCED-99-156 Sensitive Business Information Chapter 3 EPA Could
    Improve Its Efforts to Address Industry Concerns problems. Among
    these efforts, most significant is the recent creation of an
    Information Office that will be headed up by a senior-level
    manager who has been charged with addressing information policy
    issues, improving agencywide consistency of information policy and
    management, and obtaining stakeholders' involvement in the
    decision-making process. Although EPA acknowledges the importance
    of addressing industry's concerns about the collection and the
    dissemination of sensitive business information, no defined plans
    have been developed by EPA that detail how the new Information
    Office should proceed in doing so. Given the long-standing
    controversy over this issue, we believe EPA needs to ensure that
    the Information Office works with industries and other
    stakeholders to address these matters. Recommendation     To help
    ensure that the long-standing concerns about the collection and
    the dissemination of sensitive business information are addressed
    in a consistent, comprehensive manner, we recommend that the
    Administrator, EPA, direct the Program Manager of the new
    Information Office to develop an action plan that details how the
    office will address the issues surrounding sensitive business
    information. A central feature of this plan should address how EPA
    will balance its need to collect and disseminate potentially
    sensitive business information with industries' concerns about
    such activities. To ensure that EPA fully considers the concerns
    of all interested parties, this action plan should be developed
    with extensive and representative involvement by stakeholders.
    Agency Comments    We provided a draft of this report to EPA for
    comment and held discussions with officials from the Office of
    Information Transition and Organizational Planning. The agency
    concurred with our recommendation and offered several technical
    comments and clarifications, which we incorporated as appropriate.
    Page 25                                     GAO/RCED-99-156
    Sensitive Business Information Appendix I GAO Contacts and Staff
    Acknowledgments GAO Contacts       Gregory A. Kosarin, (202) 512-
    6526 Edward A. Kratzer, (202) 512-6553 Acknowledgments    In
    addition to those named above, Alice L. London, Joseph Cook, and
    Richard P. Johnson made key contributions to this report. (160446)
    Page 26                              GAO/RCED-99-156 Sensitive
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