I agree with you entirely. We made that point in the 1999 audit.
You have a process whereby a substance is determined to be toxic. You go through a process of identifying what you're going to do about it. Most of the time that's in the form of either a regulation or companies agreeing to voluntarily reduce the limit. The only reporting mechanism that existed at the time was the NPRI. We made the point in the chapter that many of the substances that are being declared toxic are not on the NPRI. There was no mechanism for tracking releases. By 2002 the departments had made a number of additions to the NPRI, and more and more of those declared toxics were being tracked.
I think your question remains pertinent today. That's why I said earlier that if we were approaching this topic again, we would probably go substance by substance. We would want to know what risk management measurement was in place, what reductions were you trying to achieve, what do we know about releases, and what do we know about ambient monitoring. It's one thing to know under the NPRI whether it's being released at a point facility; it's an entirely different question to know whether it's in our water, on the land, or if we're breathing it.
Most of the substances were not being monitored in 1999. I think you're onto the right thing, that if you don't have monitoring and tracking, you don't know—unless the instrument itself, like a regulation, has reporting built into it, such as an MOU sometimes. Even in a memorandum of understanding, the companies and the associations involved are often more than willing to try to report their progress. From a reliability standpoint, you have the ability to enforce a regulatory approach, but when you have a voluntary approach, we were asking the question, how do you know? And how can you use that tool to make sure it's working?
I must say, though, that on this count the Department of the Environment did respond to our recommendations. We had suggested they needed some policy guidance on when they would use voluntary instruments, when not, and what they should look like. I think we did report in 2002 that the department had made some good progress there. They actually found it quite helpful; they had some ammunition to use with industry, to say we need to have robust instruments.