No Subject

[slester@essential.org]

FYI:


The March-April edition of "Working Notes on Community Right-to-Know" 
gives the following explanation for why dioxin is not covered under the 
Toxics Release Inventory:


	When Congress set up the Toxics Release Inventory (TRI) in 1986, it set 
thresholds for reporting.  For example, a manufacturer report under TRI 
if the firm emplys ten or more full-time workers and uses more than 
10,000 pounds of a listed right-to-know chemical.
	Companies don't technically "use" 10,000 pounds of dioxin; it is 
an unintended byproduct of combustion measured in nanograms, not pounds. 
However the EPA can add dioxin to the TRI in two steps.  First, add 
dioxin to the right-to-know list.  Second, lower the use thresholds.  EPA 
can base new thresholds on classes of chemicals and categories of 
facilites.  Thus to add dioxin to TRI, EPA could set the threshold at 
"any" dioxin emissions from large combustion sources.  
	On November 9, 1994, EPA announced that it would address dioxin 
thresholds in its next expansion of TRI (along with other persistent 
bioaccumulative substances).	



Yet another loophole in reporting that allows polluters to continue to 
subject us to dioxin.  Hopefully this one will be addressed soon.
------------------------

Michael Drescher
Citizens Clearinghouse for Hazardous Waste
P.O. Box 6806
Falls Church, VA 22040
(703) 237-2249
e-mail:  cchw@essential.org