87 



(5) To help implement our codes of management practices under the Responsible 

 Cared program, CMA prepares a series of resource documents and materials to as- 

 sist companies with actual implementation. 



For ^he Product Stewardship Code, these resource materials include videotapes 

 such as The Power of Product Stewardship (explaining the unique role of sales and 

 marketing professionals), Implementing Product Stewardship (describing how the 

 code relates to key jobs in each company), and Product Stewardship: Beyond the 

 Fenceline (reviewing the main elements of the Code). Other materials focus on help- 

 ing companies launch a Product Stewardship prograim; developing a better risk 

 characterization/risk management program; and building Product Stewardship into 

 both new and existing chemical research and development, product reformulation, 

 and product process changes. 



(6) EPA's 33/50 program is an example of a voluntary initiative that has been 

 highly successful. This program, based in part on Toxics Release Inventory (TRI) re- 

 porting data, 8 derived its name from the overall goals of reducing releases and 

 transfers of 17 high-priority chemicals: a 33 percent reduction by 1992; and a 50 

 percent reduction by 1995. Seventeen (17) priority chemicals were targeted by EPA 

 in the 33/50 program including: benzene, lead, mercury, methyl ethyl ketone, tolu- 

 ene, and xylenes. 



The 33/50 surpassed its 33 percent national reduction goal a full year ahead of 

 schedule.^ The U.S. chemical industry reduced releases of listed chemicals to the 

 environment by 38 percent from 1987 — 1992, according to reports submitted to the 

 EPA. The industry reduced by 45 percent off-site transfers of listed chemicals for 

 treatment and disposal. 



To provide meaningful year-to-year comparisons, CMA analyzed the reports from 

 1,422 plants operated by its member companies and tracked 320 core chemicals, 

 that is, chemicals which have been on the TRI all 6 years. In spite of increases in 

 chemical industry production, which grew by 15 percent from 1987 to 1991, the 

 emissions trend is in the right direction down. (See Appendix A). 



More than 1,200 companies have chosen voluntarily to participate in 33/50, in- 

 cluding many CMA members. EPA and industry trade associations are working co- 

 operatively to increase the number of companies participating in the program, in- 

 cluding smaller companies. Facilities' projected emissions offer strong encourage- 

 ment that the 33/50 program's ultimate goal of a 50 percent reduction by 1995 will 

 be achieved. 



CMA's Responsible Cared Pollution Prevention Code complements the 33/50 pro- 

 gram and will surpass it in a more comprehensive way. This Code commits senior 

 management to ongoing reductions in releases to the air, water, and land and in 

 the generation of wastes. Companies must inventory wastes and releases, and 

 evaluate their potential impact on employees and the community. Reduction plans 

 are to be developed and implemented. Progress must be measured, and the public 

 informed. The code calls for periodic reviews of waste management practices, and 

 has specific provisions for contract and toll manufacturing, ground water protection, 

 and inactive plant sites. 



While TSCA has had a profound impact on our industry's culture and awareness, 

 we have chosen to go beyond EPAs mandated implementation of TSCA to make the 

 Improvements in risk management we believe are necessary and critical in a rapidly 

 changing global culture and economy. 



In your invitation to CMA, dated April 26, 1994, you identified several questions 

 which you asked us to answer. Our answers are provided below: 



Question: What do you see as chemical manufacturers' responsibilities under 

 TSCA? 



CMA believes that chemical manufacturers should produce and use chemicals, 

 subject to TSCA, that do not pose an unreasonable risk. TSCA gives EPA authority 

 to regulate products that have the potential to pose unreasonable risks. Industry be- 



8 The TRI was created by Congress in 1986 as part of the Emergency Planning and Commu- 

 nity Right to Know Act. The TRI documents releases and transfers of some 320 chemicals. 



8 Data from TRI, covering the 1991 reporting year, revealed the emissions of 33/50 chemicals 

 declined by 34 percent between 1988 and 1991. 



