chemicals that have been released by a facility into the environment. Such data provide some information about environmental performance. However, SARA TRI numbers do not take into account the fact that quantity is not the only measurement of risk. A small quantity of a potent carcinogen might pose a significantly greater health risk than a large quantity of a mild irritant.

Even with that inherent limitation, TRI reports have become the focal point for environmental groups, local communities, and the media, primarily because the numbers are easy to understand. The media find the numbers of particular value. Current and historical releases, expressed as pounds per year of a particular chemical, can easily be compared. In addition, because all major manufacturing facilities are required to file these reports annually, facilities can be compared with one another.

Such comparisons are used by environmental organizations to push plants with high releases to meet the lower emissions levels achieved by comparable facilities. There have even been suggestions that performance comparisons be required by law. Today, in air regulation, new sources of emissions in nonattainment areas are required to meet lowest-achievable rate standards—the lowest emission rate that is achieved in practice or is required by any law or regulation in that state.

Similarly, new plants could be required to meet a lowest-achievable release rate. This would be the release rate to all media achieved by a similar manufacturing facility with the best performance. This type of regulation could be extremely burdensome and raises some very disturbing issues regarding proprietary information. The basic concern is that the plants that perform best may be achieving these exceptional results through the use of proprietary technology. Could this type of legislation require these companies to share their superior yet proprietary technology with a competitor? Even if a licensing fee were offered, the mandatory sharing of such technology would create a significant monetary and competitive loss for the company that developed it.

Although there are many ways to use the SARA TRI information, data requirements and report formats are mandated by regulatory agencies. These data may not satisfy a company's needs. Thus, companies may also want to consider developing other metrics that are more useful for internal measurement of environmental performance.

Pollution Prevention at 3M

At 3M, we have quantitatively measured environmental performance since 1975. The system in use quantifies the pollution that has been prevented under 3M's Pollution Prevention Pays (3P) program and the resulting monetary savings. Within this system, 3M defines pollution prevention as source reduction and environmentally sound reuse and recycling. Although this metric does not indicate total environmental performance, it does address an extremely important issue for top management. What it tracks is the amount of pollution that has been



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