The European Commission has deferred a decision on whether to proceed with its earlier idea of a mandatory Polluting Emissions Register (PER) or to seek voluntary reporting agreements with a range of industrial sectors. Many obstacles stand in the way of such agreements, not least their capacity to deliver compliance by all relevant companies within a sector (ENDS Report 229, pp 38-39 ).
Industry bodies such as the Union of Industrial and Employers' Confederations of Europe (UNICE) oppose a mandatory PER, claiming that it would simply add bureaucracy without increasing incentives for businesses to improve their environmental performance.
However, a different perspective is emerging elsewhere. In January, the Canadian Chemical Producers Association (CCPA), founder of the "Responsible Care" programme which has now been taken up by chemical industries in many other countries, published data on its members' emissions in 1992, along with projected emission reductions by 1997. The move anticipated the Canadian Environment Ministry's plan to publish the first data collected under a mandatory National Pollutant Release Inventory (NPRI) by the end of 1994.
The CCPA required all its 58 members to report releases of 225 chemicals - including 49 not covered by the NPRI - if their production or release exceeded specified thresholds. Its report notes that members voluntarily reported releases of a further 175 chemicals and 62 mixtures which they believed to be significant to human health or the environment. These will be considered for inclusion in the report for 1993.
The report reveals which companies reported emissions of the listed chemicals. However, the data are not broken down by individual firms or sites. Further aggregated data are provided for emissions of carcinogens, ozone-depleting substances, greenhouse gases and chemicals contributing to photochemical smog creation.
Bruce Caswell, project leader for the initiative, says that the primary audience for the information is the CCPA's own membership, so as to keep them abreast of their collective efforts towards emission reductions. The Government, environmental groups and the public are seen as secondary targets, although Mr Caswell emphasised that many firms have undertaken local "community outreach" initiatives and a few have published corporate environmental reports.
However, the CCPA is also backing the mandatory approach of the NPRI. According to Mr Caswell, "having an inventory is a starting point for setting priorities for dealing with environmental issues. We need to know what is being emitted before we can decide our priorities." One of the CCPA's reasons for supporting a mandatory inventory is that it will help to put the chemical industry's own releases into perspective.
In Europe, the chemical industry has grave reservations about mandatory inventories. Mr Caswell commented: "We were the authors of 'Responsible Care' and I guess we have moved out much further along the spectrum than in other countries. Probably five years ago we would have had the same attitude, but we evolved to the point of recognising the value and need for openness and transparency over this kind of information."
The Canadian Environment Ministry says that the issue of mandatory or voluntary reporting was debated in the early stages of establishing the NPRI. The key factor proved to be industry's desire for a level playing-field in making comparisons both between and within sectors.
The NPRI is a simplified version of the US Toxics Release Inventory. Chemicals on the TRI list which are not produced in or imported into Canada were removed, as well as certain substances which are already being controlled or phased out by legislation. Common air pollutants, such as greenhouse gases and nitrogen and sulphur oxides, were also excluded because the Canadian provinces already collect release data.
Unlike the US system, the NPRI does not require firms to report on their environmental improvement plans or to provide details of individual waste streams and on-site waste treatment activities. It requires site-by-site reporting on computer disc of all releases to air, land and water and all off-site transfers of waste by plants with more than 10 employees which produce, process or otherwise use more than 10 tonnes per year of a listed chemical at more than a 1% concentration.
The NPRI is expected to cover some 2,000 firms in all industrial sectors. Estimates of transportation emissions will be included to give a fuller perspective.
Franoise Lavallee, head of the NPRI, accepts that some industries prefer the voluntary approach to improving environmental performance. But he says that "as we shift from a regulatory to a voluntary approach, the mandatory emissions inventory takes on much greater importance - you have to trade off one for the other. You can then rely on public pressure. The fact that the data is made public acts as an incentive for firms to reduce emissions."
One such voluntary programme already under way challenges industry to reduce emissions of specific toxic, persistent and bioaccumulative substances. Others will follow once the NPRI is up and running.
Meanwhile, in Sweden, the Environmental Protection Agency (EPA) is completing a pilot emissions inventory. About 100 chemical producers and users were asked to report their releases. However, the EPA says that the response has been poor because of the programme's voluntary nature.
A senior chemicals expert at the EPA, Hkan Bjorndahl, told ENDS that legislation for a national emissions inventory has been deferred until the findings of the OECD's programme on emissions inventories are published, probably late in 1995 (ENDS Report 229, pp 38-39 ).
Mr Bjorndahl is enthusiastic about the benefits of an inventory, and says that risk reduction programmes are futile without a comprehensive baseline from which to set priorities. He also hopes that an inventory will enable the EPA to perform materials balance calculations for chemicals used or consumed by industries compared with releases into the environment, as waste or into products.
Some sectors of Swedish industry, such as chemicals manufacturers, are already required to submit an annual report to local authorities on their efforts in pollution prevention, assessments of environmental impact and data on emissions of individual chemicals. However, many firms have not provided details of all their emissions. The EPA feels that it can improve compliance by implementing a national inventory based on a well defined list of chemicals covering many sectors.
However, the Swedish Chemicals Industry Association (SKI) is non-committal about the idea of an inventory until more details are available. It points out that the EPA is legally obliged to justify the grounds for a national emissions inventory, estimate its costs and negotiate its structure with bodies representing the industries concerned.
Elsewhere, Dutch chemical firms could soon find themselves subject to new laws under which they will have to publish detailed reports about their environmental impacts and performance and pollution prevention and reduction initiatives. A Bill to that effect is now before the Dutch Parliament (ENDS Report 222, p 40 ).
Meanwhile, in Australia, the Environmental Protection Agency is consulting on a proposed national pollution inventory, which it says will be broadly based on the US TRI.