The toxic release inventory: fact or fiction? A case study of the primary aluminum industry

Since 1989 manufacturing facilities across the USA must report toxic chemical emissions to the EPA's toxic release inventory (TRI). Public release of this information and increased public scrutiny are believed to significantly contribute to the over 45% reduction in toxic chemical releases since inception of the program and to growing support for this type of informational regulation instead of traditional command-and-control. However, prior research indicates a tendency to under-report emissions. We find specific evidence of under-reporting of polycyclic aromatic hydrocarbons (PAH) to the TRI by primary aluminum facilities after promulgation of the industry's maximum available control technology (MACT) standard in 1997. We also find evidence of dislocation of emission overseas due to these regulatory requirements. Additionally, changes in energy prices affected aluminum production and further distort reported PAH emissions levels. This suggests the possibility of more widespread under-reporting that is modulated by various factors, including market conditions and new regulations, and which may partially explain the downward trend in TRI emissions. It also suggests that the quality of TRI data may improve once facilities are subject to monitoring of emissions of a TRI listed pollutant due to command-and-control regulation.