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ACROSS THE POND Assessing REACH's First Big Impact on U.S. ...

ACROSS THE POND Assessing REACH's First Big Impact on U.S. ...

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ENVIRONMENTAL DEFENSE FUNDWhat else can’t t the public see?EPA’s s reporting methods obscure data that aren’teven claimed CBI.• Uses <strong>on</strong>ly broad aggregate ranges instead ofchemical-specific data or ranges for:– Producti<strong>on</strong> volume (yet <strong>on</strong>ly 20-30% is CBI)– # of processing sites, workers (28% CBI)• Use of <strong>on</strong>ly Yes/No indicators and chemicalcounts instead of chemical-specific data for:– Industrial processing/use (26-49% CBI)– Commercial/c<strong>on</strong>sumer use (26% CBI)• No data <strong>on</strong> % of producti<strong>on</strong> volume provided29

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