Your web site has improve significantly since its release last year. It also contains very important information.

"The considerations necessary when using TRI data in scientific studies (and suggested approaches for researchers)".

Individuals often discuss individual data limitations, but never as a complete tool kit and seldom with approaches to address the limitations when using TRI data. I have seen where researchers well respected in their fields make common mistakes by making the wrong assumption as to what a specific data element means or how it may have been reported to the EPA. Typically the mistakes become apparent when certain data trends are applied at too fine a scale or an assumed exactness is attributed to the data.

So far site is not very user friendly. Tried to look at/download a couple of talks, Michael Ash's and my own and either timed out (Firefox) or got an error in Internet Explorer: Security Error Loading Document info: 'Error #2048'.

Kirk Mills

Colorado SARA Program

*comments are of the writers, and not sanctioned by his employer.

** Writer is a past TRI state Contact, also past FOSTA-TRI Member, and past NPPR Board Member

changes, expansion, improvements:

- revisit TRI expansion (phase IV?) which was looking at materials balance, including adding the chemical USE numbers.  We've had this data in MA since 1989.  for a company to accurately report their emissions, they MUST know how much they used in the first place, it adds value, adds information that can be used for better risk analysis (transport of materials to the facilities has risk (spills, accidents on highways, rail, shipping), and can be cross referenced with TIER II data as well

- add chemicals, a MA draft law has text that say's something like 'commerce has added 80,000 chemicals to production, while MA tracks some 1400'... while TRI tracks some 700 chemicals, this highlights the tremendous lack of information that exists.  If the TRI is truly for the "Community Right to Know", how can the "community" possibly know what the chemicals and risks are if over 75,000 chemicals used are NOT being tracked?

- add nano materials as a 'category'.  While the quantity manufactured and used may be well below the current 'high' thresholds, use the PBT case to expand to gather nano material information.  Explore the legal situation to see if the FTE count in this unique instance can be lowered as well.  Apply the precautionary principle to make this 'happen' (little is known, compounds are in commerce, and there is little to nothing known about the short term impacts/risks, and less known about the long-term impacts/risks.  if a nano material is used in a consumer product, what happens to it 1-100 years after it's intended use, and then what happens when it is 'thrown away (recycled, burned, land filled) ?

- add additional SIC/NAICS codes.  Again, MA has added additional codes and we have gathered additional information from facilities such as commercial laundries, waste-to-energy plants.  Add feed lots (corporate farming), the environmental impact of these facilities is often much greater than any 'factory'.

- remove some chemical exclusion (i.e.: ammonia is currently reportable only if it is fuming.  Is it not dangerous if it is liquid? )

- remove some USE exclusions (i.e.: the exclusion that allows beef (meat?) processing facilities to be exempt from reporting the levels of DIOXIN that are in the meat that they are processing)?

- add GHG chemicals to the mix

- make use on the forms the FRS ID#, if implemented this could greatly add to the transparency (to use a popular term) of corporate responsibility.

- Or, use FIEN# (with FRS ID#?)

- merge Tier II reporting (storage on-site) with TRI

- 'mine' the various databases @ EPA and other sources to find potential inconsistencies and non-filers

Finally, stop supporting 2 systems for transmitting TRI data to the states (EPA web site & CDX).  Since CDX data retrieval is expensive & complex, and 'only' 22 (?) states are forecast to use it, leaving the rest of the states without access, build the EPA web site for TRI to a point where a state (or anyone) can download the data (all), allow them the same (or better) 'front end' interface so that they can build reports, make comparisons and massage the data any way needed - and download/import the result.

I thought this conference was well balanced and focused on new things that we need to do in the program. Location was great. I know it is heard to come up with subjects and speakers for the sessions but I think ECOS did a great job to balance the Agenda from industry perspectives to environmental perspectives.

This was only my second trip to the National Conference.  I do confess that my EPCRA knowledge was very limited in '08 but with more than a year's experience "under my belt", '09's session was that much more enjoyable.  Many thanks for the scholarship...without it, I would not have been able to attend this outstanding forum.  I do agree with entertaining the idea of making this an every-other-year event to allow more time for topics/issues to develop along with the opportunity for EPA Regions to collaborate with their state counterparts on ways to enhance the TRI program.

And finally, I was very pleased to hear more discussion on the quality of TRI data.  In SC, we participate in the SDX program.  So when a facility electronically reports to EPA, they automatically meet the reporting requirements of my state and no additional quality checks are performed upon their air emissions data.  However, if problems with the data are detected (i.e., we typically discover that facilities over-report their air emissions to TRI by one or more orders of magnitude when compared to our state emissions inventory), we promptly notify the EPA Regional office of our findings.  

It goes without saying that accurate TRI data is crucial to the success of EPCRA, NEI, NATA, and RSEI.  Communities base manpower and resources on these data sources to address issues of human and environmental health.  It is hoped that as future TRI submissions come in, less discrepancies in the data are detected.

The discussion concerning industry segments not currently included in TRI reporting came up.  My state (SC) has a municipal waste incinerator that emits > 25 lbs of Hg on an annual basis.  Although it meets the EPCRA reporting criteria under Section 313, it is exempt from doing such via CERCLA. 

The Obama administration's "push" to get things done is admirable; however, we must not lose sight of the fact that good scientific practices and acceptable applied scientific knowledge must not be forgotten in the process.  For example, is 60 days and 10 samples (in response to the USAToday study) enough information to draw logical conclusions over the ambient air concentrations community schools are experiencing?  What kind of defensible health values and conclusions can be drawn from such a limited database?  Expeditious methods (i.e., "quick-fix") appease the public and look good in the eyes of the press, but sound scientific approaches "carry the day". 

Sorry...wrong day...see day 2

It would be great if EPA could use the website to help network researchers.  Many of us are in contact, but not all.  A central location hosted by EPA might help.

Also, keep inviting researchers to this training event -- we have things to learn and things to teach too.

Just FYI.  Maybe put it in the "Other Resources" category?