Better communications help. Regulatory flexibility can also help. The primary benefit of consolidated reporting is that fewer man-hours will be spent reporting data to the government and fewer hours will be spent by the agency in processing the data once it is received. However, there are other benefits that have environmental significance. Consolidated reporting has the additional benefit of giving the business the opportunity to look at a larger picture of chemical use.
Small companies are able to manage the entire company at once.
Likewise, if chemical data and use is managed as a whole, problems and opportunities become more evident. If the report only addresses air emissions, the use of a specific chemical may not be in sufficient quantities to pass a reporting threshold. However, if that same chemical causes TRI reporting, a waste restriction or a discharge limit, the business may be able to see that through consolidated reporting. In effect, consolidated reporting presents an opportunity for pollution prevention by highlighting the emissions, effluents, and waste as a whole and not in parts. While we think EPA has done a good job at improving its communication with the regulated community, it has not succeeded in reducing the reporting burden.