We are a nation of laws and regulations that are, for the most part, intended to create and maintain order and structure. Environmentally, we have regulations and permits designed to limit discharges (air, water, waste) to our environment, protecting not only the environment, but the health of those individuals in the surrounding communities. Compliance with these various regulations and permits is the job of the United States Environmental Protection Agency (EPA) and states with delegated authority.
One of the things that makes the process of environmental compliance increasingly difficult is when activists do what amounts to “kicking the beehive.” Suggesting that local companies are “soulless corporate polluters” and the local community is a helpless victim puts both the company and the community in a difficult position.
TRI for Communities – conveying the right message?
However, sometimes I think, unwittingly, that our nation’s regulators do the same thing. What I am referring to, specifically, is company reporting under the Toxic Release Inventory (TRI) and the conveyance of messages under TRI for Communities. The “delivery” of these messages can make it difficult for local employers to have a good relationship with their neighbors.
As way of an example, in a recent effort to reach out to communities, and, apparently specifically, to Hispanic Communities, the Environmental Protection Agency (EPA) has provided a “comic-book style introduction to TRI, in both Spanish and English.” So far so good; after all, education sheds light, removes mystery, and avoids misunderstandings.
Furthermore, according to the EPA, “The Community Right-to-Know provisions help increase the public’s knowledge and access to information on chemicals at individual facilities, their uses, and releases into the environment.”
But, it becomes troubling for me personally in the way the message is delivered. In this “comic-book” depiction (below), the main character states in part,
“…there is a law that says certain factories must tell us how much pollution they are creating. They must also tell us what types of chemicals they are producing and sending out of their smokestacks, out of pipes, into the water and or the land.”
In the spirit of an episode of Seinfeld, let me offer a more effective way to communicate this same message.
“…we are fortunate to live in a nation that allows us easy access to information about the types of chemicals and processes that our local manufacturing companies use. Our state and federal environmental regulators regulate, permit, and in some cases monitor, compliance activity and they will share this information with the community.”
Informing the community that a local company is creating pollution and sending it out into the community just seems, unnecessarily, verbally “loaded” to me. We don’t look at our individual activities as creating pollution, although everything we do does create a “pollution footprint” (driving our cars, consuming food, heating/cooling our homes, the use of modern technology, breathing, etc…).
And, while it may be seen as a minor point, a “factory” cannot report anything. It is individuals, who are typically well educated members of the community, who possess their own, learned ethics, who report.
Source: TRI for Communities http://www2.epa.gov/toxics-release-inventory-tri-program/tri-for-communities
As someone who has grown up in the era of environmental protection and who majored in the environmental sciences, I support a clean environment. As someone who has worked with the regulated community for a very long time, I also understand that compliance is challenging. It is made even more challenging when the regulated community is made out to look as if they are carelessly “creating pollution” and “sending out chemicals” into the air and onto the land.
In my nearly 40 years of work in the environmental business, I have never heard any of my clients request that I find a way to “skirt the law” or do anything that might jeopardize human health and the environment. Does it happen? Certainly. But I would venture the educated guess that those unscrupulous are the rare exceptions.
No one wants to see another Bhopal, India incident (this was the genesis for the Emergency Planning and Community Right to Know Act). But no matter how unintentional, portraying our local manufacturing companies as potential villains is, at least in my opinion, counterproductive.
Working towards science-based solutions that are practical and bounded by realistic regulations will not only help protect our local communities, but will also help the jobs that keep our communities viable.
If you have remarks regarding this commentary, you can direct them to me (ahahn@dragun.com). If you have questions about environmental compliance issues, contact Matthew Schroeder (mschroeder@dragun.com) at 248-932-0228, ext 117.