David Fischer Authored Article on the Reporting of Dioxin Compounds

Keller and Heckman Counsel David Fischer authored the Inside EPA's Risk Policy Report article, “Making ‘The Best’ Better: Toward a More Useful Method of Reporting Dioxin and Dioxin-like Compounds.” The article discusses the Environmental Protection Agency’s (EPA’s) 1999 final rule on reporting releases of persistent, bioaccumulative, and toxic (PBT) substances under the Toxics Release Inventory (TRI). The rulemaking was controversial for a variety of reasons including EPA’s decision to create the astonishingly low reporting threshold of 0.1 grams for the newly added dioxin and dioxin-like compounds category – over 10,000 times lower than the next lowest threshold level of 10 pounds. Facilities that inadvertently manufacture dioxin and dioxin-like compounds above the 0.1 grams threshold may now be subject to reporting release data for this category of compounds. 

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