Accounting and the Environment

“If all the accountants in the world were laid end to end – it would be a good thing.”

I used to tease my husband while we were in grad school with this quote. He was working toward a masters in economics, and at the time he was taking a series of honors accounting classes. His usual comeback was “I don’t want to be an accountant. I want to be the accounting boss. You have to understand what you manage.”

OK, entirely off-topic, right? Not really. There is a corollary to my husband’s philosophy: You cannot manage what you do not understand. Perhaps it is because I was in the throes of TRI (Toxic Release Inventory) report preparation that the topics of accounting and regulating came to mind. The vagaries of my interests tend to lead to some odd philosophical thoughts. This one caught my attention when it flitted through, and I decided that it was worth at least a brief essay attempt.

For those of you who do not know, TRI reporting is required every year for any industrial facility that ‘processes’ or ‘otherwise uses’ any of a list of 581 chemicals or 30 chemical categories above the reporting thresholds. If the threshold is exceeded, the facility must then account for what happened to that chemical through the facility processes that resulted in releases to each of the three environmental media:
• How much was emitted to the air?
• How much was released into surface water?
• How much was released to the land (i.e., managed in onsite waste management units or was sent off site for disposal)?

And my favorite: how much is projected to be released into the various environmental media in each of the next two years? Talk about polishing your crystal ball. After this past year, clients are quite uncertain about their production projections for the next month, let alone the next year!

Anyway, the data gathered is now submitted through the USEPA’s Central Data Exchange where it is compiled, validated, confirmed, and finally put out on TOXNET for perusal by the public. The TOXMAP feature is really quite interesting, and contains a phenomenal amount of data. You can, literally, see what is released in your back yard.

From an industry perspective, I know I anticipate the TRI reporting cycle with a dread akin to my annual visits to the OB/GYN (apologies to any male readers - you can insert dentist, if you prefer, but trust me, this analogy is more apt). It doesn’t matter how conscientious I am about my accounting practices, I always find something I’ve missed before. I spend so much time worrying about whether I’ve accounted for everything, I have little time, or energy, left over to actually make any headway on managing what I’ve measured, let alone understanding exactly why changes may have occurred.

Also, who selected the 581 chemicals and 30 chemical categories? Are these the worst, most toxic chemicals? Are there other chemicals that I should worry about? I always start with what I reported on the SERC (State Emergency Response Commission) report for the year, since its reporting requirements are much broader. But there isn’t always a lot of correlation, since the SERC reporting is based on the product, while the TRI reporting is based on specific chemicals, which may be in the products, some at low percentages. I also look at the air reporting, but it is done in even broader terms like volatiles and particulates (an exception being hazardous air pollutants, which generally do require individual emission tracking). In short, the TRI reporting really does end up being a process onto itself.

And while I applaud the collection and dissemination of data, I wonder, does it help to make our environment any cleaner? I fully adhere to the idea that you cannot manage what you do not understand (read as ‘measure’) but when has the measurement gone so far that we lose sight of the need to manage?

I finished the TRI reports for two clients on time (due July 1) – woot! For one client, I found a chemical that I missed last year. It’s a small percentage of a product, but they use enough of the product that the threshold was exceeded. We’ve made strides in reducing use of the nastier products at the facility. This particular one is really a fairly innocuous material, overall. It just happens to have a small percentage of a TRI chemical in it. Turned out that there was very little ‘released to the environment,’ but it was processed over the threshold so it has to be reported. Feels like the time I spent on this was a colossal waste.

I shouldn’t complain. This is what keeps me in business. But it irks me when it just seems like a bunch of busy work with no real benefit to the environment. Maybe that’s my general problems with the regulatory framework in the U.S. as a whole; a lot of busy work with little benefit; a self-sustaining bureaucracy that has lost touch with its intended purpose.

It is disheartening to me that picking up trash with my 4-year-old along the road feels more environmentally-relevant than performing my work as an environmental manager.

Go figure – literally.