S. 2800 is important legislation. It is important for today but it may have greater value in the future as the impact of federal environmental regulations is extended to smaller and smaller companies. EPA and the states continue to make improvements in the quality of the information they provide to businesses. Nevertheless, the level of information required from business increases each year.. More importantly, the size of the companies that must report is getting smaller.
The Clean Air Act, the major environmental program affecting the U.S. printing industry, now applies to companies as small as fifteen employees in some areas of the country. In fact, most urban areas consider all printers as major sources of air pollution because the industry is a large area source. While it is true that the majority of printing companies do not have "site specific" federal air permits now, unless we change the Clean Air Act, more and more of these companies will have the same permit requirements as large printers. In addition, virtually every printing company has some level of reporting requirement for waste, chemical storage, or water discharge. Any steps we can take now to make reporting easier for these companies will pay significant dividends.
For smaller companies, reporting can be a complex and sometimes error prone process. These companies often lack the tools and experience to provide the information. Often small companies have to rely on suppliers or Material Safety Data Sheets to determine the volatility or toxicity of a chemical. The level of complexity is also a factor in the rate of error. The more complex the reporting requirement, the greater the chance of error.
S. 2800 could provide significant help in reducing the time required to file. If the reporting is consolidated into fewer reports, it is possible that the rate of error will be reduced simply by minimizing the time required to fill out forms.
In the real world of business, particularly manufacturing, changes in the last few years have been astonishing. Printing, one of the nation's largest manufacturing industries, is threatened by new media, the cost of supplies, increased postal rates, a lack of skilled labor and the imposition of federal and state regulations. Reports of streamlined regulations and reinvention have been grossly overstated. Companies that have been reporting are still reporting, and new companies are being added regularly. With each new threat, companies in our industry meet the challenge by reducing costs in every facet of the company. In many cases, this means reducing the expertise a company might have to handle state and federal regulatory reporting. Nationally, a very small number of PIA members have environmental specialists.
One federal statute, the Clean Air Act, gives a good indication of the expansion of reporting requirements. The Act categorizes businesses as sources of emissions, not by how much they emit, but by their potential emissions. Further, the Act imposes significant controls on states to reduce pollution. Printing companies are capital intensive. Commercial printers in a community want to be in a position to offer a wide range of printing options which means they will likely have more equipment than they need. While this may make good sense from a customer service standpoint, EPA evaluates each of these presses by its potential to emit. In simple terms, a printing company has the potential to emit a great deal more than it could ever hope to emit. In an industry such as printing where there are a significant number of small companies, very small companies can become major sources as defined by the Clean Air Act.
We have worked with EPA in an effort to improve the "potential to emit" rules. If these rules are clarified favorably, some printing companies may no longer have to report as major sources.
In terms of reporting burden, it is not unusual for a printing company to file quarterly, semiannual, as well as annual emission reports. A printer may also have to file an additional state annual emission statement with a different format and data element presentation requirement to a different branch of the same media program. Some air programs such as Title V can also require additional annual reports when mandatory annual training is completed. These various annual reports have different deadlines.
These companies must also account for any significant changes. Purchase of a new press or an expansion of the facility triggers other series of reports including new permitting, new source review, and more. Frankly, we do not believe Congress considered the purchase of new equipment in a small business as an event triggering new source review, but that is where we are today.
In light of these concerns, we think S. 2800 provides an opening to some genuine reporting reform. Reporting on an issue by issue basis is inefficient for many businesses. In the case of a smaller printing company, the most accurate reporting is by inventory or use of input materials, not outputs such as emissions, effluents, and waste generation. Companies buy a certain quantity of inks, solvents and other chemicals. The process of accounting for these chemicals provides information about emissions and waste. Additionally, inventory accounting may also indicate areas where changes can be made to reduce or eliminate problems. Inventory accounting can be more accurate.
Another benefit of consolidated reporting is to improve the EPA's "inventory" of pollutant loadings. One of the ongoing disputes we have with EPA is the emissions inventory. EPA determines the emissions inventory and the emissions of particular industries through emissions factors. These factors are not changed often enough to account for new technology. Since printing has been through a technology revolution in the past decade that some compare to the invention of movable type, old data is worthless data. Regulatory decisions and targets of emission reductions are based on emissions inventories and emission factors that do not reflect current emissions. If the data making up the inventory and the factors are incorrect, the regulatory action itself may be incorrect. In the case of printing, we believe change in technology alone has resulted in substantial reduction of air emissions, but it is difficult to get credit for these changes in the current information system.
It is my opinion that the challenge facing EPA is not a lack of desire to make the changes. Instead, the lack of success may be due to the statutory "balkanization" of EPA into media programs. Each of these programs has developed data that is important to the individual program. There is almost certainly a level of concern about a proposal such as this that would consolidate such data into a single point. Data is a form of power.
One question about this legislation is why is it necessary? The nation has embraced technology, and the internet will make electronic information exchange easy. While these statements may be true, it is not necessarily true that EPA or any other federal agency will place a high level of priority on such consolidated reporting. Part of our concern is based on an experience we had with OSHA in attempting to get them to embrace electronic Material Safety Data Sheets. While OSHA would permit electronic systems, it required redundant paper systems as a back up to the electronic system. Obviously, this defeated the purpose of the electronic systems. OSHA has changed its attitude about electronic MSDS's, but it was not a smooth transition.
This experience tells us that if we want consolidated reporting, it will be necessary to legislate it. It is our hope that the legislation goes where EPA would go anyway.
Would EPA accomplish the same goal absent legislation? For some of the reasons stated above, we do not. EPA's priority is the environment. From the environmental community side, that means enforcement. From the business side that means communication and regulatory efficiency. Enforcement tends to win this battle. However, at some point, every constituent of EPA must realize that improvements in data gathering also help improve the environment. 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. We cannot find a single example of a company that has had its actual reporting burden reduced through EPA's One Stop Reporting program. If this legislation will produce results, it is worth the effort to pass it.
We urge your support and prompt action on S. 2800. 1999 U.S. MARKET SEGMENT BREAKOUT
Establishments Employment
Shipments ($M)
COMMERCIAL PRINTING
General Commercial Printing* 22,629
382,932
$49,328.7
Quick Printing* 7,853
57,837
$5,291.7
Magazine Printing 269
38,274
$5,970.8
Newspaper Printing 5,319
202,376
$28,880.8
Book Printing 356
54,807
$7,109.0
Financial, Legal Printing 179
14,811
$2,242.1
Screen Printing 1,347
26,816
$2,708.6
Thermography 278
8,371
$1,141.5
Total 38,230
786,224
$102,673.2
FORM, LABEL & TAG PRINTING
Business Forms Printing 807
42,397
$8,154.3
Label, Wrapper Printing 834
37,160
$5,229.5
Tag, Ticket, Tape Printing 150
6,482
$911.7
Total 1,791
86,039
$14,295.5
GREETING CARD PRINTING
Total 55
4,023
$616.3
SPECIALTY PRINTING
Total 992
42,954
$6,224.5
PACKAGING PRINTING
Total 1,714
146,945
$22,088.4
TRADE SERVICES
Prepress Services 5,092
70,133
$7,272.1
Trade Binding 721
20,121
$1,390.1
Other Finishing Services 815
16,954
$1,151.0
Total 6,628
107,208
$9,813.2
TOTAL U.S. PRINTING 49,410
1,173,393
$155,711.1
*The small commercial printing (<10 employees) and quick printing market totals:
Total 23,068
119,602
$10,746.0