If the data making up the inventory and the factors are incorrect, the regulatory action itself may be incorrect. In the case of printing, we believe change in technology alone has resulted in substantial reduction of air emissions, but it is difficult to get credit for these changes in the current information system. It is my opinion that the challenge facing EPA is not a lack of desire to make the changes. Each of these programs has developed data that is important to the individual program. There is almost certainly a level of concern about a proposal such as this that would consolidate such data into a single point.
Data is a form of power.
The nation has embraced technology, and the internet will make electronic information exchange easy. While these statements may be true, it is not necessarily true that EPA or any other federal agency will place a high level of priority on such consolidated reporting. Part of our concern is based on an experience we had with OSHA in attempting to get them to embrace electronic Material Safety Data Sheets. While OSHA would permit electronic systems, it required redundant paper systems as a back up to the electronic system. Obviously, this defeated the purpose of the electronic systems.