EPA began working to establish such a system in 1995, but those efforts have since fallen behind other priorities. Graham notes that an identification number would make it easier for other governmental entities and the public to use the Toxics Release Inventory (TRI)database in combination with other databases -- a position OMB Watch has long advocated. Coincidentally, EPA’s information chief, Kim Nelson, has plans to advance the use of a facility identification system.

Ideally, such an identification system should be put in place across government, allowing the public to call up a particular facility from one location on the web and get most or all the information it reports to the government, including TRI data, any OSHA infractions, SEC data, etc. As it currently stands, no such integrated system exists, making the data much less powerful. Similarly, there is a need for a corporate identification system so that it is known who owns various facilities.

Also part of the prompt letter, Graham advises EPA to adopt a system that would allow facilities to report data electronically at a single entry point -- which would be aided by establishing a single identification system for each facility. Such a system, Graham suggests, would improve data quality, provide a comprehensive data set for use by government and the public, and eliminate duplicative reporting requirements and the associated burden on regulated facilities for making multiple submissions of the same data to EPA.

Finally, Graham advises EPA to find ways to expedite the yearly release of TRI data, which has been slow coming in recent years. Graham suggests that EPA encourage greater use of electronic reporting by respondents in order to reduce transcription and the quality control burden on the agency. Graham notes that the quality control burden should be on the reporting industry -- not on EPA -- though EPA currently shoulders this burden.

Previously, OMB Watch has been critical of Graham’s use of prompt letters -- of which five have been issued so far -- questioning whether OIRA, with its limited staff and expertise, should be so aggressively engaged in agenda setting for which the agencies are statutorily charged. Yet we are less concerned in this case -- and not just because we happen to agree with him. Like a previous prompt letter to FDA on trans fatty acid, Graham is highlighting activity that the agency itself has declared important and initiated. While the prompt letter may not be the right tool, EPA should be held accountable for not taking these important steps to improve dissemination to the public.