It is important to note, that while collection of the six data elements provide extremely valuable information, they do not, by themselves measure P2. Other data is needed in many cases, such as the amount of waste not generated due to source reduction, data presently collected only in New Jersey. The six chemical use data elements are considered by state and local officials in Massachusetts and New Jersey to be a valuable addition to the current data collected in both states. However, the Roundtable recognizes that industry as well as state and local governments are not homogeneous and consequently, EPA needs to be careful in how it expands TRI chemical use reporting nationwide. A national program will need to consider the diversity of all of the important stakeholders as well as several difficult issues, in order to achieve the same success enjoyed in New Jersey and Massachusetts.
Industry has the right to trade secret protection.
Another important issue is the overall net reporting burden faced by industry. The Roundtable strongly advocates that a reduction in reporting requirements be a prerequisite to the expansion effort. For example, industry is asked to report on numerous other types of activities under other statutes such as the Resource Conservation and Recovery Act and the Clean Water Act. If that same information were coherently consolidated and publicized along with the existing TRI information, it would answer many of the public's frequently asked questions and paint a more comprehensive picture of the environmental impacts of industrial facilities. Moreover, it would seriously reduce the reporting burden on industry by eliminating the need to file redundant reports.