the toxics use reduction act in massachusetts: a successful model in toxics substitution and...
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The Toxics Use Reduction Act in Massachusetts: A Successful
Model in Toxics Substitution and Reduction
The Toxics Use Reduction Act in Massachusetts: A Successful
Model in Toxics Substitution and Reduction
Joel A. Tickner, ScD
Lowell Center for Sustainable Production
November 24, 2003
Joel A. Tickner, ScD
Lowell Center for Sustainable Production
November 24, 2003
Summary Summary
TUR Provides a successful model for chemicals management that includes understanding how chemicals are used and ways to reduce use/waste in the first place
TUR is a particularly useful technique for downstream users
There are many lessons from TUR that could inform the emerging EU system
TUR Provides a successful model for chemicals management that includes understanding how chemicals are used and ways to reduce use/waste in the first place
TUR is a particularly useful technique for downstream users
There are many lessons from TUR that could inform the emerging EU system
Evolution of Pollution Prevention in the US and TUREvolution of Pollution Prevention in the US and TUR
1986 OTA Report – Serious Reduction of Hazardous Waste
1990 Pollution Prevention Act State Programs
• Toxics Use Reduction Act of 1989
Federal and International Programs
1986 OTA Report – Serious Reduction of Hazardous Waste
1990 Pollution Prevention Act State Programs
• Toxics Use Reduction Act of 1989
Federal and International Programs
Goals of TUR
50% reduction in the generation of toxic by-products by 1997 through TUR
Establish TUR as the preferred means of regulatory compliance
Sustain and promote the competitive position of Massachusetts industry
Promote reduction in the production of toxic and hazardous substances
Enhance and coordinate state agency enforcement of environmental laws
What is TUR Toxics Use Reduction?
Toxics Use Reduction Act Definition: In-plant changes in production processes or raw materials that reduce, avoid, or eliminate the use of toxic or hazardous substances or generation of hazardous byproducts per unit of product, so as to reduce risks to the health of workers, consumers, or the environment, with out shifting risks betweenworkers, consumers, or the environment. TUR shall be achieved through any of the six defined techniques.
Definition of TUR: Key Points
In-plant changes that reduce, avoid, or eliminate the use of toxic or hazardous substances or
generation of hazardous byproducts Per unit of product Reduce overall risks to workers, consumers, and the environment Without shifting risks Through TUR techniques
The Six TUR TechniquesThe Six TUR Techniques
1. Input substitution
2. Product reformulation or redesign
3. Equipment or technology modernizations
4. Process or procedure modifications
5. Improvements in housekeeping, maintenance, training, or inventory control
6. In-process recycling
1. Input substitution
2. Product reformulation or redesign
3. Equipment or technology modernizations
4. Process or procedure modifications
5. Improvements in housekeeping, maintenance, training, or inventory control
6. In-process recycling
Planning and Accounting Process
Regulations define content, not process TUR concentrates on planning:
• Process Characterization• Process mapping• Materials accounting
• Options generation/screening• Technical/financial analysis• Implementation
TUR should become center-piece of regulatory structure
Listed ChemicalsListed Chemicals
Several government lists accounting for about 1000 chemicals (Toxics Release Inventory, CERCLA)
Chemicals on list because of some hazard they pose (chronic, acute, etc.)
Companies to file based on using chemical not risk
About 170 Chemicals actually reported About 560 Companies reach thresholds
Several government lists accounting for about 1000 chemicals (Toxics Release Inventory, CERCLA)
Chemicals on list because of some hazard they pose (chronic, acute, etc.)
Companies to file based on using chemical not risk
About 170 Chemicals actually reported About 560 Companies reach thresholds
The Heart of Planning
Compile data for current materials use, toxics use, production processes• Serves as base-line for all future TUR possibilities• Provides comprehensive view of current work practices – why
chemicals being used and how• Indicates areas of high toxics use, or inefficiency• Identifies opportunities and options• Involves employees in all aspects of facility
TUR Planning ProcessTUR Planning Process
Planning cycle when viewed as a continually improving
Planning cycle when viewed as a continually improving
Implement
Evaluate
Review
Continual Improvement…
Modify
Evaluate
ReviewPlan
(year 0)
Update (year 2)
Plan Contents – Facility-Wide Info
Pre-Plan
ProcessCharacterization
Identify TUROptions
ImplementPlan
MeasureSuccess
Certify Plan
Develop orUpdate Plan
Screen & Evaluate TUR
Options
Management Policy Statement•Mission statement to clarify philosophy
•and commitment to TUR and P2 initiatives
Plan Scope•Summary of Universe ID process
•Summary of TUR to be implemented
•Description of Production Units
•List of chemicals
Employee Notification•Six months prior to Planning (January 1)
•Informs employees and requests input
Plan Contents – Process CharacterizationPlan Contents – Process Characterization
Pre-Plan
ProcessCharacterization
Identify TUROptions
ImplementPlan
MeasureSuccess
Certify Plan
Develop orUpdate Plan
Screen & Evaluate TUR
Options
Process Mapping• Visual representation of production units
• Show where chemicals enter and leave
Process
Calculate costs of toxics
Material Balance• Determine amounts of toxic used
• Determine amount of by-product
Plan Contents – Options ID
Pre-Plan
ProcessCharacterization
Identify TUROptions
ImplementPlan
MeasureSuccess
Certify Plan
Develop orUpdate Plan
Screen & Evaluate TUR
Options
Identify the universe of TUR options• ID all techniques for potentially achieving
toxics use reduction
• METHODS: Brainstorming techniques,
vendor info, trade associations
Plan Contents – Options EvaluationPlan Contents – Options Evaluation
Pre-Plan
ProcessCharacterization
Identify TUROptions
ImplementPlan
MeasureSuccess
Certify Plan
Develop orUpdate Plan
Screen & Evaluate TUR
Options
Screen the universe • Determine and eliminate options that
are clearly technically or economically
infeasible
Detailed evaluation• Technical evaluation
• Economic evaluation
•Health Safety and Environmental Evaluation
•Tools and support to complete
Develop implementation schedule• Determine timeline for implementation
• Project toxics use reduction 2 and 5
years into the future
Plan Contents – Plan DevelopmentPlan Contents – Plan Development
Pre-Plan
ProcessCharacterization
Identify TUROptions
ImplementPlan
MeasureSuccess
Certify Plan
Develop orUpdate Plan
Screen & Evaluate TUR
Options
Document all aspects of the Plan or
Plan Update• Keep plan on site – do not submit to DEP
Submit Plan or Update summary • Certification statement
• Projected changes in toxics usage
• Projected byproduct reduction
• Types of TUR techniques
• Other useful info for public review
•Public available information
Plan Contents - CertificationPlan Contents - Certification
Pre-Plan
ProcessCharacterization
Identify TUROptions
ImplementPlan
MeasureSuccess
Certify Plan
Develop orUpdate Plan
Screen & Evaluate TUR
Options
Plan must be certified by:• DEP Certified TUR Planner
• Senior Plant Manager
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TURA Program Agencies Bureau of Waste Prevention, DEP
• Implementation/enforcement Office of Technical Assistance
• Voluntary technical assistance - engineering Toxics Use Reduction Institute Funded by fee on chemicals use
Administrative Council
Bureauof Waste
Prevention
Toxics UseReductionInstitute
Office ofTechnicalAssistance
ScienceAdvisory
Board
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Toxics Use Reduction Institute
Develops and delivers a curriculum for TUR Planners Sponsors and conducts research into technologies,
methods, and policies which decrease risk to the environment and human health• ie Surface Solutions Laboratory
Provide technical support and technology transfer to industry, government and the public – stakeholder engagement
Provide information on TUR to all education levels Assist in training inspectors and other key toxics personnel Library of toxics use reduction information/databases
website www.turi.org
New DirectionsNew Directions
Priority User Segments PBTs High Hazard Chemicals Environmental Stewardship – Blue Ribbon
Panel Supply chain collaboratives Community based initiatives Toxics in everyday products
Priority User Segments PBTs High Hazard Chemicals Environmental Stewardship – Blue Ribbon
Panel Supply chain collaboratives Community based initiatives Toxics in everyday products
Results of Toxics Use ReductionResults of Toxics Use Reduction
Results: 1990-2000
• 60% reduction in waste
• 40% reduction in use
• 80% reduction in emissions Benefits to industry $15 million (not
considering health/environmental benefits)
Helps that state is a chemical using one
Results: 1990-2000
• 60% reduction in waste
• 40% reduction in use
• 80% reduction in emissions Benefits to industry $15 million (not
considering health/environmental benefits)
Helps that state is a chemical using one
Did We Achieve the Goals?
Lessons Learned – Information NeedsLessons Learned – Information Needs Need for good process/facility level materials
accounting information• Materials not efficiently managed (what you can’t
measure you can’t manage)
• Identifies opportunities for greater efficiency
• Provides a more holistic view
• Protection of CBI generally not requested
Need good metrics to measure progress Need good information on alternatives to problem
substances REACH currently focuses on only toxicity
information (and some use) – materials flow data would enhance supply chain understanding
Need for good process/facility level materials accounting information• Materials not efficiently managed (what you can’t
measure you can’t manage)
• Identifies opportunities for greater efficiency
• Provides a more holistic view
• Protection of CBI generally not requested
Need good metrics to measure progress Need good information on alternatives to problem
substances REACH currently focuses on only toxicity
information (and some use) – materials flow data would enhance supply chain understanding
Lessons Learned – Planning NeedsLessons Learned – Planning Needs Particularly important for downstream users as a
framework to consider means to reduce/eliminate problem chemical use through efficiency and substitution measures – focus on service of chemical
Engages wide range of actors in decision process
Considers whole process/facility hazards Chemical substitution often means process
change• Consideration of product quality/economics
• Consideration of health and safety trade-offs
Substitution/prevention planning with clear guidance would be important under REACH
Particularly important for downstream users as a framework to consider means to reduce/eliminate problem chemical use through efficiency and substitution measures – focus on service of chemical
Engages wide range of actors in decision process
Considers whole process/facility hazards Chemical substitution often means process
change• Consideration of product quality/economics
• Consideration of health and safety trade-offs
Substitution/prevention planning with clear guidance would be important under REACH
Lessons Learned - InnovationLessons Learned - Innovation Innovation requires both willingness AND
capacity Technical support has been critical for industry
innovation • Demonstration projects/sites
• Networking of firms
• Research support
• Technical assistance to firms
• Success brings more interest/successes
Recognition of leaders through Governors’ awards
Failure to consider could lead to disjointed REACH implementation
Innovation requires both willingness AND capacity
Technical support has been critical for industry innovation • Demonstration projects/sites
• Networking of firms
• Research support
• Technical assistance to firms
• Success brings more interest/successes
Recognition of leaders through Governors’ awards
Failure to consider could lead to disjointed REACH implementation
Conclusion: Lessons from Toxics Use ReductionConclusion: Lessons from Toxics Use Reduction
Have Ambitious Goals Metrics and planning are critical to prevention
– understanding how materials are used and options for reduction
REACH should encourage firms to consider implications of chemical substitutions
Support research and technical assistance for innovation
Using a multitude of tools to achieve goals of REACH
Have Ambitious Goals Metrics and planning are critical to prevention
– understanding how materials are used and options for reduction
REACH should encourage firms to consider implications of chemical substitutions
Support research and technical assistance for innovation
Using a multitude of tools to achieve goals of REACH