United States General Accounting Office

GAO Report to Congressional Committees

September 1998 ENVIRONMENTAL

INFORMATION

Agencywide Policies

and Procedures Are

Needed for EPA’s

Information

Dissemination

GAO/RCED-98-245

GAO United States

General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-280580 

September 24, 1998

The Honorable Christopher S. Bond

Chairman

The Honorable Barbara A. Mikulski

Ranking Minority Member

Subcommittee on VA, HUD,

 and Independent Agencies

Committee on Appropriations

United States Senate

The Honorable Jerry Lewis

Chairman

The Honorable Louis Stokes

Ranking Minority Member

Subcommittee on VA, HUD,

 and Independent Agencies

Committee on Appropriations

House of Representatives

U.S. industry uses hundreds of millions of pounds of toxic chemicals each

year in producing the nation’s goods and services. Release of these

chemicals during their transport, storage, use, or disposal as waste can

potentially harm human health and the environment. In 1984, a

catastrophic chemical accident at a plant in Bhopal, India, killed

thousands of residents, injured many others, and displaced many more

from their homes and businesses. In the wake of this event, the Congress

passed the Emergency Planning and Community Right-to-Know Act of

1986 (EPCRA). Among other things, the act provides access by individuals

and communities to information regarding hazardous materials in their

localities. Section 313 of the act generally requires facilities that

manufacture, process, or otherwise use toxic chemicals to report the

amounts of various toxic chemicals that they release to the environment

and requires the Environmental Protection Agency (EPA) to make this

information available to the public, which EPA has done in a national

database known as the Toxic Release Inventory (TRI). Under section 312 of

the act, employers must provide an inventory of hazardous chemicals

present at their facilities. This information must also be made available to

the public through state and local agencies.

Over the past several years, EPA has expanded the number of reporting

facilities and the number of chemicals for which data on their releases are

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reported to the TRI. The agency is also considering expanding the type of

information reported for the TRI to include detailed data on the use of

these chemicals at these facilities. Reflecting concern that communities

need data on the risks posed by local toxic releases and that EPCRA may

already provide communities with sufficient data on the use of chemicals

at these facilities, the conference report accompanying the VA, HUD, and

Independent Agencies fiscal year 1997 appropriations bill1

 and subsequent

discussions with your staff directed us to determine the status of EPA’s

efforts to (1) provide communities with risk information on toxic chemical

releases in their areas; (2) make EPCRA’s chemical inventory information

publicly accessible; and (3) develop policies, procedures, and standards

for disseminating environmental information to the public.

Results in Brief EPA has three projects under way that would provide additional data to

communities on releases of toxic chemicals from nearby manufacturing

facilities. Although these projects are not being designed to

comprehensively define an individual community’s risks, collectively, they

would substantially expand the information available to communities. In

addition to the Toxic Release Inventory’s quantities of chemical releases,

this information is to include data on individual facilities’ history of

compliance with environmental laws, the relative toxicity of chemical

releases, the dispersion of the releases to surrounding areas, and the

estimated concentrations of the chemicals in the outdoor air from sources

not covered by the Toxic Release Inventory, such as other facilities and

motor vehicles. However, each of these initiatives has a different scope

and time frame for completion, and it could be several years before the

initiatives’ full promise would be realized. In addition, the availability to

the public of certain data in the first of these projects—the Sector Facility

Indexing Project—was delayed because of concerns from state and

industry officials about the data’s accuracy and how the information may

be interpreted by the public.

Although the data from the chemical inventory that is reported under

section 312 of the Emergency Planning and Community Right-to-Know Act

are potentially useful for such purposes as a citizen’s finding out what

chemicals are used at a nearby facility, public use has been limited. Much

of the information has not been computerized to provide easy access and

when it has, it is not available in regional or national databases that permit

comparisons among industries or geographical areas. EPA estimates that

868,500 facilities provide local emergency planning committees, fire

1

House Report 104-812.

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departments, and the states in which they are located with data on

thousands of hazardous chemicals. Industry representatives have stated

that the substantial costs of providing the information would be better

justified if the public made more use of it. In recent years, EPA has taken

some steps to assist local and state efforts to computerize the data, and

two EPA regions have initiated efforts to consolidate computerized state

databases. While EPA believes that such efforts might prove to be

worthwhile, it has not provided funding for nor assessed the potential

benefits and costs of developing a national computerized database for this

information.

EPA has not developed policies, procedures, and standards to govern key

aspects of its projects to disseminate information, such as the Sector

Facility Indexing Project. For example, EPA does not have in place

agencywide policies and procedures specifying standards and detailed

guidance for analyzing whether the information to be disseminated meets

users’ needs and for obtaining stakeholders’ involvement in designing the

projects. EPA also has not developed standards to assess the data’s

accuracy and mechanisms to determine and correct errors. While EPA has

several initiatives under way to improve its data management practices, it

has no specific plans to provide its program offices with guidance for

designing, developing, and implementing their information dissemination

projects.

Background Section 313 of EPCRA generally requires facilities at which toxic chemicals

are manufactured, processed, or otherwise used to report annually to EPA

and the states on, among other things, releases of these substances. The

requirement applies to facilities with 10 or more full-time employees in

specified industries that exceed the chemical reporting thresholds

specified in the act. EPA makes the data in the TRI available and accessible

to the public in various formats, including a computerized database on the

Internet. The Pollution Prevention Act of 1990 expanded the information

collected in the TRI to include data on the industries’ efforts to reduce

pollution at its source and on recycling. EPA has further expanded the TRI

by, in November 1994, requiring reports on additional chemicals and, in

May 1997, requiring reports by additional industrial groups. In

October 1996, EPA also announced that it was considering an expansion

that would require industries to report the amounts of toxic chemicals

entering a facility, transferred into products and waste, and leaving the

facility. This concept has been referred to as “materials accounting” or

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“chemical use data.” EPA expects to propose a rule on this requirement in

1998.

The TRI currently contains data on the amounts of over 600 chemicals that

have been emitted to the environment (the air, water, or land) and/or

transferred off-site as waste. Although this information on a nearby

facility’s releases provide some indication of potential risk to human

health and the environment, local communities also need information on

the chemicals’ toxicity—the degree of danger to animal or plant life—and

the extent of their exposure to the releases to more fully understand the

risks. Even the most toxic chemicals do not cause harm to an individual

unless sufficient exposure occurs. More specifically, comprehensive risk

information includes data on (1) what chemicals have been released, how,

where, and in what amounts; (2) what toxicities are associated with

exposure to each chemical and how toxic that chemical is; and (3) who

has been exposed to the chemical and how often, to how much, and for

how long. The TRI’s information on the amount of releases represents

estimated aggregate amounts for a full reporting year. Additional details

on the duration or timing of these releases would be needed to more fully

understand the risks. For example, a chemical release may be more severe

if the releases are concentrated over a short period, rather than occurring

in smaller amounts over an entire reporting year.

Almost from the start of the TRI program in 1987, EPA has been asked by

communities and other users to expand the inventory to provide them

with more information on the risks posed by the chemical releases. More

recently, in its April 1995 report on EPA, the National Academy of Public

Administration (NAPA) recommended that the agency add risk factors to

the TRI.

2

 According to NAPA, the TRI is a useful, but incomplete, tool to

inform the public and company officials about toxic releases. NAPA said

that, by linking risk information to the inventory’s chemical reports,

businesses would have an incentive to reduce the most hazardous

emissions first.

Under section 312 of EPCRA, employers must annually submit a hazardous

chemical inventory form to designated state and local emergency planning

organizations, as well as local fire departments.3

 The form generally

contains information regarding the amount of hazardous chemicals

2

Setting Priorities, Getting Results: A New Direction for EPA, NAPA (Apr. 1995).

3

Under section 301 of EPCRA, the governor of each state appoints a state emergency response

commission, which then designates local emergency planning districts and appoints a local emergency

planning committee for each district.

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present at a facility, by category, as well as their general location. The

designated recipients of the inventory form may request more detailed

information, such as specific chemical identities and exact locations, from

individual facilities. The public may generally obtain information

submitted under section 312, although the exact locations of chemicals

must be withheld under certain circumstances. While section 313 of EPCRA

requires TRI reporting on the emissions of over 600 chemicals by

approximately 22,000 facilities, section 312 of EPCRA requires reporting on

thousands of hazardous chemicals that are present at an estimated 868,500

manufacturing and nonmanufacturing facilities.

In September 1997, EPA announced, as one of its strategic goals, the

expansion of the public’s right to know about the environment. In

addition, EPA announced, as a principle to guide senior management’s

decision-making and priority setting, that agency actions should maximize

public participation and community right-to-know efforts. In making this

announcement EPA stated its intent to empower state, local, and tribal

governments and the American public by providing citizens with

information to help them make informed decisions regarding

environmental issues affecting their communities. To do this, EPA said that

it would expand the content of its databases, improve the data’s quality

and usability, and make the data widely available through the Internet and

other sources.

EPA’s Efforts to

Provide Communities

With Information on

the Risks Posed by

Toxic Chemical

Releases

Although EPA does not have any plans to expand the TRI to include

information on the human health and environmental risks posed by toxic

chemical releases, the agency has three projects under way that will

provide communities with substantially more data on nearby facilities, the

relative toxicity of their chemical releases, and the potential exposure to

the releases. Two of these projects—the Relative Risk-Based

Environmental Indicators Project and the Cumulative Exposure

Project—are efforts by EPA to use toxic release data and other information

to improve the agency’s consideration of potential health and

environmental risks in setting priorities and developing policies, primarily

to identify specific chemicals, sources of chemical emissions, or

geographic areas for priority action to reduce risks. The other project—the

Sector Facility Indexing Project—provides information on the facilities

and their environmental performance, including the amounts of their toxic

releases and their history of compliance with environmental laws. EPA

recognizes that these projects separately and collectively are not definitive

assessments of risks to individual communities. Nonetheless, the projects

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could expand the information available to the public on the facilities and

toxic releases in their areas.

EPA’s plans to make the earliest of these projects—the Sector Facility

Indexing Project—publicly available generated considerable concern on

the part of industry and some states over the accuracy and

appropriateness of the data for public use. EPA made substantial efforts to

identify and correct the data’s inaccuracies and decided to delay including

the information on the toxicity of chemical releases, which was

controversial with industry and the states, before the project’s data were

made available on the Internet in May 1998. Unless addressed first, similar

issues about stakeholders’ involvement, the data’s accuracy, and how the

information may be interpreted by the public are likely as EPA makes the

results of other projects available to the public. For example, the toxicity

information that EPA was considering for the Indexing Project is a

component of the Relative Risk-Based Environmental Indicators Project.

EPA Does Not Plan to Add

Comprehensive Risk

Information to the TRI

According to TRI program officials, EPA has no plans to expand the data in

the TRI to incorporate toxicity and exposure information. The officials said

that, when the Congress was considering the passage of EPCRA, the issue of

whether the TRI should contain risk information was debated and it was

decided that information on the amounts of toxic releases, which are

referred to as hazard information, would be sufficient. The officials further

stated that the TRI has worked well in encouraging industry to reduce toxic

releases and that it is not practicable to develop and add the information

that would be needed to provide the public with accurate assessments of

the risks from TRI releases in specific communities.

In its annual summary reports of TRI releases, EPA has added discussions

on the potential health and environmental effects of the covered chemicals

and on the factors involved in assessing risks. General information on the

use and the potential effects of chemicals is also available from various

other sources within and outside EPA. For various toxic chemicals, the

agency is preparing fact sheets that describe how they are generally used,

how exposure to them might occur, what happens to them in the

environment, and how they affect human health and the environment.

The information needed to assess risks is often not available. Data on the

amounts, the durations, and the methods of individuals’ exposure to

chemicals is generally limited, and little is known about the toxic effects of

many of the chemicals used in commerce. According to EPA, for 43 percent

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of the chemicals produced in high volumes, no data from tests on their

basic toxicity currently exist. In April 1998, Vice President Gore directed

EPA to proceed with the Chemical Right-to-Know Initiative, which is to

accelerate the collection and dissemination of information about widely

used chemicals to which people, especially children, may be exposed.

Major aspects of the initiative involve getting industries to provide more

complete test data on chemicals that are produced in high volumes and to

perform additional testing for chemicals that children are most likely to

encounter as well as having EPA review persistent chemicals that

accumulate in body tissues to determine whether these chemicals should

be subject to TRI reporting or to lower thresholds for reporting.

The Sector Facility

Indexing Project

The Sector Facility Indexing Project, which was initiated by EPA’s Office of

Enforcement and Compliance Assurance in 1995, provides extensive

information through the Internet on over 600 facilities in five major

industries: (1) auto assembly; (2) iron and steel production; (3) petroleum

refining; (4) pulp manufacturing; and (5) primary smelting and refining of

aluminum, copper, lead, and zinc. The project consolidates information

that has been available to the public through different data systems,

publications, and several places on the Internet. For each facility, the

project provides information on its location, production or production

capacity, surrounding populations, and permits held under major

environmental programs; the number of inspections received; its record of

compliance with federal regulations; and any chemical releases, spills, or

transfers off-site. According to EPA, facilities can use this project to

compare their data against those of similar facilities or simply to monitor

their own regulatory performance. Government agencies can use the

information as a planning tool, for example, to identify facilities for

assistance in complying with regulations. Environmental and community

groups will have easier access to information that they can use to learn

about the environmental performance of facilities near them.

EPA plans to evaluate the project and may then expand it to include other

industry sectors and more types of data. For example, the agency is

examining ways to add data about chemicals that are reported under other

statutes, such as the Clean Air Act, and data on the toxicity and relative

risks of toxic releases—this information is being considered under the

Relative Risk-Based Environmental Indicators Project. EPA had earlier

proposed to include the toxicity information, but industry and states

expressed concerns about the accuracy of the information and whether it

would mislead the public about the risks posed by chemical releases.

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According to a project official, the agency received comments from many

stakeholders that the toxicity data did not go far enough in examining the

potential risks and that the risk components should be factored into the

project along with the toxicity information. The project official said that

toxicity information allows users to examine where potential hazards

might be without respect to whether the population might be affected,

whereas relative risk-based analysis examines potential interactions

between chemical releases, toxicity, weather patterns, chemical dispersion

properties, and surrounding populations. The official stated that

incorporating relative risk-based information into the project is a

long-term goal.

The Relative Risk-Based

Environmental Indicators

Project

EPA’s Office of Pollution Prevention and Toxics initiated the Relative

Risk-Based Environmental Indicators Project to use TRI’s release

information as a measure of the impact of EPA’s efforts to improve the

environment. The project involves developing a computer model that

assigns numeric values to individual risk elements, such as the amount of

chemical releases, the chemical’s toxicity, and estimates of exposure and

exposed populations, so one chemical release can be compared to

another. For example, a value is assigned for the toxicity of the chemical

release from a weighting index that reflects the toxicity of the chemical

relative to others. Similar values are calculated for the other elements and

these can then be added together to arrive at a “risk-based” value for a

particular release at a facility. In turn, the values for all of a facility’s

releases can be summed to be analyzed for trends over time or compared

with those of other facilities.4

According to EPA, the project will enable potential users to analyze the

relative risks of releases by medium (i.e., air, water, or land), chemical,

geographic area, industry sector, specific facility, or a combination of

these and other variables. As a result, users will be able to examine trends

or to rank and prioritize the releases for strategic planning, risk-related

targeting for enforcement and compliance, and community-based

environmental protection purposes.

The model is being tested by EPA’s regions, states, and tribal groups and

may be made available to a wide audience of users later this year. The

model, however, will only provide an indicator value for chronic human

health effects through exposure via the air. It will not address acute

4

The project’s purpose is not to formally assess the risks from chemical releases in order to estimate

the number of illnesses potentially resulting from a specific toxic release, for example.

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human health or ecological effects or other pathways of exposure, such as

water.5

 The model is expected to eventually (1) provide for potential

chronic and acute human health and ecological effects and other exposure

pathways and (2) incorporate additional census data that will allow users

to analyze the effects of chemical releases on exposed populations by such

demographics as race, age, and income. According to EPA, the indicators

model must often rely heavily on certain assumptions about individual

sites because the information is generally not available. Because the model

does not produce a formal risk assessment, it is to be used primarily as a

risk-screening tool rather than an attempt to quantify the potential health

risks to individuals at the community level.

The Cumulative Exposure

Project

EPA’s Office of Policy, Planning, and Evaluation is developing the

Cumulative Exposure Project as a priority-setting and policy development

tool. The project is intended to use existing data and methods to estimate

a national distribution of cumulative exposures to environmental

pollutants, including those reported under the TRI. Because people tend to

be exposed through multiple ways to numerous pollutants originating

from a variety of sources, EPA proposes to estimate cumulative exposures

by combining measured and modeled concentrations of pollutants in the

air, food, and drinking water with human activity and consumption

patterns. (The TRI’s data are used only for the project’s air pollutants

component.) The ultimate goal is to develop analyses of multiple

exposures and multiple pollutants, thereby providing EPA with the ability

to identify the potentially most significant environmental exposures

(among those considered in the project) and the most affected

communities or demographic groups. According to EPA, this information

will enhance the consideration of cumulative exposures to pollutants in

developing environmental policy.

The project’s air pollutants component uses the TRI, other data from EPA on

emissions, and a model from EPA on the dispersion of pollutants in the

atmosphere to estimate the outdoor concentrations of 148 hazardous air

pollutants (also referred to as air toxics) that are regulated under the

Clean Air Act. In addition to enabling users to compare concentrations

across regions, states, and census tracts, estimates can be developed for

subpopulations and for the relative contributions to outdoor

concentrations from broad sectors of the economy, such as transportation,

5

Acute toxicity refers to any poisonous effect produced by a single short-term exposure that results in

severe biological harm or death. Chronic toxicity is the capacity of a substance to cause long-term

poisonous human health effects.

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manufacturing, and waste management.6 The significance of the

concentrations for a specific census tract can be determined by comparing

them to a set of benchmark concentrations derived by EPA from available

data for carcinogens (cancer-causing agents) and noncarcinogens.7

Officials from the Cumulative Exposure Project expect to complete the air

toxics component and make the results publicly available through the

Internet by the end of calendar year 1998. This component of the project

will provide estimates of the concentrations in the outdoor air of the 148

hazardous air pollutants for 1990 only. EPA’s Office of Air and Radiation

plans to use the project’s model to measure the success of its efforts to

control air pollution in reducing exposure to hazardous air pollutants.

Data for succeeding years will be needed to determine trends and

progress, and the office is planning updating the data. According to project

officials, the database is large and adding additional years will be

labor-intensive. In addition, EPA’s Science Advisory Board, which was

established in the Office of the Administrator to provide advice on

scientific matters, urged the agency to expand its efforts to measure

concentrations of air toxics as part of its work to assess cumulative

outdoor levels of air toxics. The Board concluded that the overall

conceptual framework for the project was sound but noted that the

project suffers or will be handicapped, at least in the near term, from

limitations in available data based on actual measurements of

concentrations of air toxics.

Opportunities Exist to

Increase Accessibility

of Chemical Inventory

Data

Although the data reported under section 312 of EPCRA can be valuable to

local emergency planning committees in their efforts to develop

emergency plans and to reduce emergency personnel’s exposure to

harmful chemicals, the use of the data by the wider public has been

limited. The data are compiled on a community and state basis and often

are not computerized for easy access. Moreover, the lack of an integrated

database makes it extremely difficult, if not impossible, to compare

facilities within an industry or to perform regional or national studies or

comparisons. During the past few years, two EPA regions have initiated

projects to integrate state databases. One of these projects also was

intended to assess the potential for a national chemical inventory

database. This project was terminated due to other priorities and then

resumed with its purpose solely to create a regional database. Although

6

For census-taking purposes, the United States is divided into over 60,000 tracts.

7

These previously defined benchmark concentrations for cancer and noncancer health effects are

based on standard toxicological references and represent levels of air toxics above which health risks

may occur.

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EPA considers a national computerized database potentially worthwhile,

the agency has no specific plans to assess the feasibility for such a

database.

Chemical Inventory Data

Can Be Valuable, but Their

Use Is Limited

Local emergency planners can use the chemical inventory data to develop

plans needed to respond to emergencies, such as spills of hazardous

materials in factories. Fire departments and other emergency responders

have access to the data to help develop response plans before they arrive

at the scene of a chemical accident or at a fire at a facility using hazardous

chemicals. People who are considering buying or renting housing nearby

also can use the data to learn about the chemicals that are present in that

community.

Individual citizens, as well as various local groups, can also use chemical

inventory data to improve their ability to protect human health and the

environment by engaging in dialogues with industry representatives about

reducing chemical risks, preventing accidents, and limiting chemical

exposure. According to local emergency planning officials, environmental

consultants and attorneys also have requested this information to perform

environmental site assessments in compliance with federal and state laws,

and environmental groups have requested it to perform studies of

chemical risks. The news media may also be interested in this information

to inform the public about chemical releases that may have occurred

during accidents.

Although chemical inventory data can be useful to local citizens, the

information has not been used extensively. A 1994 nationwide study

performed for EPA under a cooperative agreement found that most local

emergency planning committees received few inquiries from local

residents for the data. During the period from June 1993 through

June 1994, about 80 percent of the local emergency planning committees

that were considered to be functioning received six or fewer inquiries, and

more than 40 percent received no inquiries. Eight of the 10 officials of

state emergency planning commissions and 19 of the 20 officials of local

emergency planning committees that we talked to said that demand for the

data was low in their geographic areas.8

8

For each of the 10 states having the highest emissions of chemicals according to EPA’s 1995 report on

the TRI, we interviewed an official of the state emergency response commission and officials of two

local emergency planning committees. The planning committees selected were among those most

notable for their efforts in conducting public outreach on the availability of chemical inventory data,

according to the state emergency planning commissions.

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Industry representatives have expressed concern about this low use,

considering their costs to report the data. EPA has estimated that providing

the data will cost industry $247 million during the period from February

1997 through January 2000, and industry representatives have maintained

that the costs would be better justified if EPA took actions to improve

access to and use of the data. For example, a major oil refiner, concerned

about the cost and limited use of the data, suggested that EPA take

responsibility for ensuring that the data are computerized to improve

access to them. Furthermore, a major industrial trade association said that

EPA should make better use of the data before it seeks additional

information from industry, such as through its plans to expand reporting

requirements for the TRI.

Computerization Could

Enhance the Data’s

Usefulness

While local emergency planning committees and state emergency response

commissions are not required to computerize their data, computerization

could make the chemical inventory data more useful to the public. For

example, according to state and local officials, potential users can more

easily aggregate and manipulate the data. EPA has supported efforts to

computerize the chemical inventory data. For example, in 1996, EPA’s

Chemical Emergency Preparedness and Prevention Office provided

$822,000 in computer software to local emergency planning committees

and state emergency response commissions to increase their capabilities

to computerize their data. A 1997 nationwide study performed for EPA

showed that 39 percent of the local emergency planning committees had

computerized their data and an additional 42 percent planned to do so.

Because of the lack of computerized data, copies of the individual

completed reporting forms have to be located and reviewed.

The officials from the local emergency planning committees and from the

state emergency response commissions that we interviewed generally

believed that access to and use of the chemical inventory data would

potentially improve if the data were made available through the Internet.

Once available, the data could be used to present different environmental

scenarios. For example, in early 1998, an environmental organization used

the data to make available on the Internet an accident scenario that

showed the number of people vulnerable to potential accidental releases

at 10 facilities that were operated by a major chemical manufacturer. The

same analysis also provided environmental data showing the percentage of

minorities at risk near each of those facilities.

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Although none of the local or state officials in our sample had placed

chemical inventory data on the Internet, they generally said that they

would consider doing so to potentially increase public use of the data.

Some states not included in our sample are using or planning to use the

Internet to provide such data. Recently, Idaho has used $75,000 in grant

funds from EPA’s Chemical Emergency Preparedness and Prevention

Office to computerize the state’s chemical inventory data and put that

information on the Internet. Oregon plans to make its chemical inventory

data available on the Internet within the next year.

A June 1998 EPA-proposed rule on EPCRA discusses, among other things, the

potential for streamlining facilities’ reporting of the data by reducing the

requirement for reporting to state emergency response commissions, local

emergency planning committees, and fire departments to one central

database that would be accessible to all three entities. EPA also suggests

that a statewide database on the Internet would provide greatly expanded

public access.

EPA’s Efforts to Integrate

Databases Could Improve

the Usefulness of Chemical

Inventory Data

Once chemical inventory data have been computerized, their usefulness

can be enhanced by integrating the data from various local and state

databases to obtain a fuller understanding of the chemicals being stored

and used throughout the country. We noted that officials in EPA regions I

and IV recently initiated projects designed to integrate chemical inventory

data from state databases and to make the data available on the Internet.

In 1995, Region IV (Atlanta) initiated work to integrate data from eight

states in the region and to make the integrated database available to users

of the data in each of those states. According to a regional official, it is

expected that the automated database will be available by the end of fiscal

year 1999. While the Region IV project is designed to provide a regional

database, another project started by EPA Region I (Boston) envisioned a

national database of chemical inventory data. In January 1995, Region I

initiated a feasibility study for the database and, in October 1996, awarded

a contract for developing software needed to integrate the databases of

the six New England states located within the region. Region I intended

that the integrated database for the six states would be a prototype leading

to a computer system for EPA, the states, environmental groups, and the

public to use in accessing national chemical inventory data. With an

integrated system, data formats would be the same throughout the country

and this would enable users to make comparisons among individual

facilities throughout the nation; would provide for local, state, and

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regional comparisons of chemical inventories; and would enable users to

discern national trends for the quantities of individual chemicals and

groups of chemicals.

Although EPA’s Chemical Emergency Preparedness and Prevention Office

endorsed the Region I project, it did not provide any funding, and in

June 1998, the region terminated the software development contract

because of higher regional priorities. Subsequently, in July 1998, Region I’s

manager for that project told us that the region had resumed the project by

using regional staff resources. According to the project manager, five of

the six states in the region had information in the database and data from

the sixth state will be added. At this time, it is uncertain whether EPA will

use the regional database as a prototype for a national database.

An official from the Chemical Emergency Preparedness and Prevention

Office told us that it is understandable that Region I had earlier terminated

the project to focus on other priorities because no legislative mandate

exists for EPA to develop either a regional or national database for this

information. Nonetheless, the official said it would be regrettable if EPA did

not have the opportunity to examine the effectiveness of such databases in

making chemical inventory data more accessible and useful to current and

potential users. According to the official, his office is concerned that,

although EPCRA does not provide for EPA to receive the chemical inventory

data and does not make the agency responsible for ensuring that they are

accurate, states and industry may hold EPA accountable for the data’s

quality if the agency aggregates the data from state databases and makes

the information available to the public in either regional or national

databases. The official said that the data would have to be aggregated from

states using varying formats and data elements for the information.

Agencywide Policies,

Procedures, and

Standards for Public

Availability of Project

Results Have Not

Been Established

EPA’s recent efforts to publicly communicate environmental information

have brought objections from some state and industry stakeholders who

provide and/or use the data. Such stakeholders have stated that, while they

generally favor EPA’s publicly disseminating data under the agency’s

“right-to-know” authorities, they are concerned about the manner in which

EPA’s data dissemination projects have been managed. For example, in

questioning the accuracy of EPA’s data, state representatives have stated

that inaccurate or misleading information provided to the public would

result in the unproductive use of federal and state resources in clarifying

the data. Industrial stakeholders stated that EPA has not adequately

involved them in its information dissemination initiatives and does not

Page 14 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

have appropriate agencywide policies, procedures, and standards

governing decisions about disseminating data, including mechanisms to

identify and correct errors, such as outdated information on facilities in

violation of the environmental terms of their operating permits.9

 State and

industrial stakeholders have discouraged EPA from publicly reporting

environmental data without assessing their accuracy and effectively

communicating to potential users the limitations that should be placed on

using the data (e.g., communicating the limitations that apply to using the

data as an indicator of risk to human health).

According to industrial stakeholders, EPA has not collaborated with them

to identify and resolve concerns prior to disseminating environmental

information. For example, industry stakeholders told us that the Sector

Facility Indexing Project had been in existence for more than a year

before they became aware of it and requested that EPA hold a public

meeting to invite their input on the project. Comments from the public

meeting, held in May 1997, raised concerns about inaccuracies in the data

and a lack of clarifications accompanying the data to help users

understand their potential uses and limitations. The stakeholders also

maintained that, when they brought errors to EPA’s attention, they found

that the agency had not established procedures to identify such errors or

to correct them after they are found and reported by others.

In response to stakeholders’ concerns, EPA held meetings with state and

industry representatives to discuss the accuracy of specific data and

procedural problems and then incorporated changes based on these

meetings, prior to releasing the data from the Sector Facility Indexing

Project on the Internet in May 1998. The changes included correcting

errors in the data, explaining limitations on how the data can be used, and

establishing a feedback mechanism to report errors in the data. However,

industry representatives told us that EPA still lacks agencywide policies,

procedures, and standards necessary to govern future data dissemination

activities, including a clear set of ground rules for stakeholders’

participation in data administration. They believe that individual EPA

offices currently are given too much authority in determining the value of

their projects to potential users and in deciding procedural issues, such as

the requirements for the data’s accuracy and the extent of stakeholders’

involvement in the projects’ design and development.

9

During our review, we interviewed representatives of four industry sectors included in the Sector

Facility Indexing Project and representatives of the Coalition for Effective Environmental Information.

The coalition represents a variety of industry segments, including petroleum refining, plastics,

electronics, forest products, chemicals, and consumer products.

Page 15 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

To discuss the concerns about the data’s accuracy and procedures that

had been raised by state, industry, and other stakeholders, we met with

EPA officials responsible for each of the three projects. Although EPA had

not established agencywide policies, procedures, and standards for

guiding the design of the projects and the release of the information to the

public, the officials maintained that, in carrying out the projects, they have

made efforts to consider the users’ needs, to obtain outside review, and to

respond to concerns over accuracy and other issues as they arose. For

example, an official of the Sector Facility Indexing Project said that EPA

worked for 3 years to identify the facilities to be included in the project

and to collect and verify the data. According to the official, each of the

facilities received a copy of its compliance and enforcement data for

review to help ensure that any problems were identified before the

information was distributed, and before the facilities’ review, EPA had

asked the states to review the data and make appropriate changes.

According to the official, facilities commented on the accuracy of

4 percent of the 38,000 major data elements they received for review and

about half of their comments were accepted for changes. The official told

us that this high rate of accuracy indicates that industry was objecting to

the project because of how the information may be interpreted rather than

its inaccuracy.

EPA has taken several agencywide actions to address concerns that

stakeholders have raised about EPA’s information dissemination processes.

For example, in April 1998, EPA’s Deputy Administrator announced that the

agency’s Chief Information Officer will lead an effort to develop a strategic

plan to implement an agencywide approach to improve the quality of EPA’s

data. He said that the plan should address the specific roles and

responsibilities of program offices and stakeholders and that one of the

principal components of the plan should be a strategy to help ensure that

“our error correction process is well-defined, efficient, and transparent to

our partners, the public, and the regulated community.” Initially, the plan

was targeted for completion by September 30, 1998, but the Chief

Information Officer told us that EPA now plans to have a draft completed

by that date and to submit it for review by EPA’s Common Sense Initiative

Council during its October 1998 meeting.10 The Chief Information Officer

and other EPA officials responsible for the plan’s development told us that

the plan is a high priority within the agency and that it is being closely

coordinated with the Office of Reinvention and the agency’s newly

10The Common Sense Initiative Council was established by EPA in October 1994 as the agency’s

national advisory committee for formulating recommendations and advice on the nation’s pollution

control and prevention programs that relate to industrial sectors and was directed by EPA to operate

by consensus decision-making.

Page 16 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

established Center for Environmental Information and Statistics, which

also plays a key role in addressing stakeholders’ concerns.

In a February 1997 announcement of plans to establish the agency’s Center

for Environmental Information and Statistics, the EPA Administrator noted

that the Center was being created to improve the agency’s collection and

management of information and to provide for better public access to

“quality-assured” environmental statistics and information. The Center’s

principal responsibilities include enhancing access to EPA’s databases,

integrating information across agency programs, boosting stakeholders’

participation in EPA’s information policy, and helping communities better

understand environmental information.

An important function of the Center is to review the degree to which EPA’s

existing databases can meet the varying demands of a wide range of

information users, including community groups, nongovernmental

organizations, and state and federal agencies. The Center currently is

leading EPA’s efforts to assess the overall quality and applicability of 31 of

EPA’s major national databases. These reviews include assessments of the

data’s accuracy and limitations. The assessments for accuracy will include

quality checks performed by EPA’s program offices as well as statistical

reviews performed by the Center. Limitation assessments being performed

by the Center will focus on identifying databases’ constraints with respect

to their primary purposes as well as their suitability for alternate uses.

EPA’s Chief Information Officer told us that his office has provided

program offices with general guidance on issues relating to information

resources management. For example, chapter 21 of EPA’s Information

Resources Management Policy Manual establishes the agency’s policy on

the public’s access to EPA’s information. This policy statement establishes

the general principles to govern the public’s access to and dissemination

of information gathered and maintained by EPA and defines the

information resources management responsibilities of the agency’s various

offices. One of the principles set forth is that new and enhanced data

systems, data collections, and databases are to be designed with

consideration of the need to permit and promote the public’s access.

However, policies and procedures for program offices to follow in

designing, developing, and implementing information dissemination

projects have not been issued.

Page 17 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

In the absence of such policies and procedures, as noted by a January 1998

EPA advisory council study,11 information management has been

administered largely through EPA’s program offices by using a

decentralized organization and management structure and has typically

been shaped by the program offices’ policies and procedures to meet the

needs of their various internal and external users. The study concluded

that inconsistencies have arisen among the programs regarding

procedures to determine the data’s accuracy, communicate the limitations

of their use, and involve stakeholders in information management

decisions.

The Deputy Director of the Center for Environmental Information and

Statistics and the Chief Information Officer told us that the Center’s role

and EPA’s strategy for improving data’s quality are evolving and, in the

future, could involve developing guidance for program offices to follow in

their information dissemination activities. The Deputy Director told us that

such guidance could include policies, procedures, and standards for

(1) setting priorities and performing cost-benefit analyses to determine

which information projects should receive agency resources,

(2) developing standards for the accuracy of data and mechanisms to

determine and correct errors, (3) obtaining stakeholders’ involvement and

analyzing users’ needs and (4) establishing other protocols that program

offices should follow in designing information dissemination projects. He

told us, however, that the Center has no specific plans to develop such

policies, procedures, and standards.

Conclusions EPA is making progress in its efforts to provide communities with more

information on releases of toxic chemicals in their areas. The data on

hazardous chemicals that facilities must provide under section 312 of

EPCRA could be another substantial source of information for communities,

if access to the data could be improved through greater computerization.

Furthermore, the value of the data could also be increased if they were

contained in an integrated regional or national database that allows for

comparing nearby facilities with others within an industry or in other

geographic locations. Although EPA’s Chemical Emergency Preparedness

and Prevention Office believes that such databases could have substantial

benefits, the agency has not assessed the potential costs and benefits of

developing them.

11Managing Information as a Strategic Resource: Final Report and Recommendations of the

Information Impacts Committee, The National Advisory Council for Environmental Policy and

Technology (NACEPT), EPA (EPA 100-R-98-002, Jan. 1998).

Page 18 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

While state and industrial stakeholders have expressed support for EPA’s

efforts to make more environmental information publicly available, some

stakeholders are concerned about how it is being done. Principally, they

are concerned about the data’s accuracy, the appropriateness of some of

the information for the public’s use, and how they have been involved in

the design and implementation of the projects. Industry representatives

have also expressed concern that the data required by EPCRA section 312

are costly to report but used little by the public. EPA has issued a policy

statement on public access to the agency’s information that provides

general principles for its offices to follow and has recently initiated steps

to develop a strategic plan to improve its information management.

However, it currently has no plans to develop implementing policies,

procedures, and standards to help ensure that its offices’ information

dissemination activities are carried out in accordance with the policy

statement.

Recommendations To help ensure that EPA provides the public with data that are accurate,

complete, and relevant to its needs, we recommend that the EPA

Administrator supplement the agency’s existing policies on information

resources management by developing agencywide policies and procedures

that specify guidance and standards for program offices involved in

designing, developing, and implementing information dissemination

projects. Such guidance and standards should address obtaining

stakeholders’ involvement in the projects’ design and development, testing

for and correcting errors in the data, and communicating contextual

information on the data’s uses and limitations.

Given the potential usefulness of EPCRA section 312 data to the public, we

recommend that the EPA Administrator evaluate options to make the data

more accessible and implement the most cost-effective option that

provides availability on a regional and national basis. In implementing the

project, EPA should use the policies and standards for dissemination

projects that we have recommended.

Agency Comments We provided copies of a draft of this report to EPA for its review and

comment. Representatives of EPA’s offices responsible for the activities

discussed in the report, including the Chief Information Officer and the

Acting Assistant Administrator for Solid Waste and Emergency Response,

said that the report, in general, accurately describes the agency’s efforts to

make information on risks from releases of toxic chemicals available to

Page 19 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

local communities, to provide the public with chemical inventory

information, and to develop policies for publicly disseminating

environmental information. The officials concurred with our

recommendation that the EPA Administrator supplement EPA’s existing

information resources management policy by developing agencywide

policies and procedures that specify guidance and standards for program

offices involved in designing, developing, and implementing information

dissemination projects. However, the Acting Assistant Administrator for

Solid Waste and Emergency Response disagreed with our

recommendation that the EPA Administrator evaluate options for making

the data collected under EPCRA section 312 more accessible and implement

the most cost-effective option to make that information available on a

regional and national basis.

The Acting Assistant Administrator said that there is no legislative

mandate for requiring industry to submit EPCRA 312 data to EPA or for using

that data to develop a national database. He also said that it would be

difficult to aggregate the data from all the states, many of which have

different reporting formats and many of which do not currently

computerize the data. In addition, the Acting Assistant Administrator said

that the Chemical Emergency Preparedness and Prevention Office does

not currently have the resources to develop and maintain such a database.

He said that the office’s current focus is on implementing section 112(r) of

the Clean Air Act, which includes developing a national database of risk

management plans that contain a wealth of information on the chemical

risks at various facilities. Furthermore, the Acting Assistant Administrator

said that any effort to develop a regional and national EPCRA section 312

database should include the involvement of the public and that it is

possible, if not probable, that the public would like to know some

information not included in the section 312 database and would not be

interested in certain data that are included.

Nonetheless, we have retained the recommendation in the report and note

that, by calling for EPA to “evaluate options” and “implement the most

cost-effective option,” the recommendation gives EPA considerable

flexibility to overcome the obstacles that the agency described. We

recognize that EPA does not have a specific legislative mandate to create a

regional or national database of EPCRA section 312 data. However, one of

EPA’s 10 strategic goals is “expansion of Americans’ right to know about

their environment,” and the agency has been and is currently involved in

various activities across its programs to make more environmental

information available to the public. Not all of these activities are

Page 20 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

specifically directed by legislative mandates. We further recognize that

EPCRA does not require industry to submit section 312 reports to EPA.

However, as agency officials noted, EPA can request the data from the

states.

We are aware that the Chemical Emergency Preparedness and Prevention

Office has limited resources and is currently working to implement section

112(r) of the Clean Air Act. Given the potential usefulness to the public,

we believe that making EPCRA section 312 data more accessible should be

considered in the context of agencywide right-to-know priorities and

resources rather than those of the Chemical Emergency Preparedness and

Prevention Office. Although certain options, such as EPA’s creating and

maintaining a unique national database of EPCRA section 312 information,

could be costly, the efforts of regions I and IV in integrating the various

databases of the states in the regions indicate that low-cost options could

be available. Although not all states have computerized databases, EPA, in

recent years, has provided grant funds to assist the states in computerizing

their data, and about two-thirds of the states have done so.

We agree that stakeholders should be involved in any effort to make EPCRA

section 312 data more accessible. In addition to the public, these

stakeholders would include emergency planning and response personnel,

who need to use the data, and industry, which must report the data.

Making more or less of this information available to meet the public’s

needs would be options to be considered in carrying out our

recommendation. In calling for EPA to adopt the most cost-effective option,

we recognize that the public’s desire for additional information would

need to be weighed against the costs of reporting, compiling, and

maintaining it.

EPA also provided some technical comments on our draft report. We have

revised our report, as appropriate, in response to these comments.

We performed our review from November 1997 through August 1998 in

accordance with generally accepted government auditing standards. (See

app. I for a detailed description of our scope and methodology.) We are

providing copies of this report to other appropriate congressional

committees; the Director, Office of Management and Budget; and the

Administrator, EPA. We will also make copies available to others on

request.

Page 21 GAO/RCED-98-245 EPA’s Information Dissemination Activities
B-280580 

If you or your staff have any questions, please call me at (202) 512-6111.

Major contributors to this report are listed in appendix II.

Peter F. Guerrero

Director, Environmental

 Protection Issues

Page 22 GAO/RCED-98-245 EPA’s Information Dissemination Activities
Page 23 GAO/RCED-98-245 EPA’s Information Dissemination Activities
Contents

Letter 1

Appendix I 

Scope and

Methodology

26

Appendix II 

Major Contributors to

This Report

28

Abbreviations

EPA Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-know Act

NAPA National Academy of Public Administration

TRI Toxic Release Inventory

Page 24 GAO/RCED-98-245 EPA’s Information Dissemination Activities
Page 25 GAO/RCED-98-245 EPA’s Information Dissemination Activities
Appendix I 

Scope and Methodology

To identify the Environmental Protection Agency’s (EPA) initiatives to

provide additional information on the risks posed by toxic chemical

releases to local communities, we held discussions with EPA’s Chief

Information Officer and officials of EPA’s Office of Pollution Prevention

and Toxics, which has responsibility for the Toxic Release Inventory (TRI)

program; Office of Policy, Planning, and Evaluation; Center for

Environmental Information and Statistics; and Reinvention Office. To

determine the status of these initiatives, we interviewed officials

responsible for implementing the projects and reviewed documents

obtained from them. We also reviewed reports and written comments on

the projects by EPA’s Science Advisory Board, state officials, and industry

representatives.

We discussed the projects and EPA’s overall efforts to provide

environmental information to the public with the Coalition for Effective

Environmental Information, which was formed by various industry firms

and groups to monitor and provide input on EPA’s public information

efforts and representatives of various firms and associations, such as

those in the mining, petroleum, and chemical industries. In addition, we

attended a September 1997 conference of TRI users and held discussions

with representatives of the Unison Institute and OMB Watch, who support

and are involved in making environmental information available to the

public.1

 To determine EPA’s policies and standards for providing

information to the public, we interviewed the Chief Information Officer

and the Deputy Director of the Center for Environmental Information and

Statistics.

We discussed how data collected under EPCRA section 312 are made

available to the public, the public’s requests for access to the data, and

ongoing and planned efforts to improve access with selected State

Emergency Response Commissions and Local Emergency Planning

Committees. Because state-by-state data on the number of facilities

reporting under section 312 are not available, we selected the State

Emergency Response Commissions of the 10 states that had the largest

amounts of TRI chemical releases. For each of these states, we selected

two Local Emergency Planning Committees that representatives of their

respective commissions indicated were the most active in improving

public access to the data. We also contacted state emergency response

commissions in two other states that were undertaking initiatives to

improve public access.

1

Building for the Future: Toxic Release Inventory and Right-to-Know Conference, organized by the

Unison Institute in cooperation with EPA, Sept. 8-10, 1997, Washington, D.C.

Page 26 GAO/RCED-98-245 EPA’s Information Dissemination Activities
Appendix I 

Scope and Methodology

We discussed EPA’s efforts to improve access to section 312 data with

officials of the agency’s Office of Chemical Emergency Preparedness and

Prevention, as well as EPA Regions I and IV, which at the time of our

review had their own projects under way. We also discussed the public’s

access to and the potential use of the data with various people

knowledgeable about that data at EPA as well as in academia, industry, and

public interest groups.

Page 27 GAO/RCED-98-245 EPA’s Information Dissemination Activities
Appendix II 

Major Contributors to This Report

Resources,

Community, and

Economic

Development Division

Washington, D.C.

David G. Wood, Associate Director

Edward A. Kratzer, Assistant Director

Raymond H. Smith, Jr., Evaluator-in-Charge

J. Kenneth McDowell, Senior Evaluator

Donald E. Pless, Senior Evaluator

Boston Field Office Bruce Skud, Senior Evaluator

(160416) Page 28 GAO/RCED-98-245 EPA’s Information Dissemination Activities
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