Our company is not comfortable with the 1988 TRI baseline because it was not a representative year. Be specific in your commitment letter. We will relate it to your TRI Reports. Our emissions are so small compared to the 1.4 billion pounds that our participation makes no difference. The reductions also will be looked at as an aggregate - total releases of all chemicals.
Companies are free to decide if and how to participate in the program.
Any steps taken to reduce targeted toxics will not be enforceable, unless these activities are otherwise required by law or regulation. Pollution reduction goals apply to total releases and off-site transfers to air, land, and water. EPA's objective is to encourage these reductions through pollution prevention. By significantly reducing the amount of pollution released to the environment. By getting faster reductions than might be achieved by waiting for statutes or regulations to take effect.