Program assessment at the 20 year mark: experiences of Massachusetts companies and communities with the Toxics Use Reduction Act (TURA) program

The Toxics Use Reduction Act (TURA) model is widely cited as an effective blend of mandatory and voluntary components, and is considered a model nation-wide and internationally. There is ample documentation of the reductions in toxic chemical use achieved by Massachusetts facilities under TURA. The present study was designed to gather other information about the experience of these facilities. Through an online survey and telephone interviews, the study investigated how these facilities are achieving toxics use reduction, how TURA affects internal company dynamics, what benefits and difficulties facilities experience, and how their experiences in the program have changed over time. Survey results indicate that the benefits experienced most frequently by facilities subject to TURA requirements are increased management attention to environmental practices; improved worker health and safety; and financial savings. Most frequently cited obstacles to TUR implementation are technical feasibility problems; financial costs; concerns about product quality; and customer requirements. Survey results also indicate that the TUR planning process is most useful in the first and second planning cycles, although most respondents indicated that they sometimes identify useful TUR options in subsequent planning cycles as well. Over all, the results indicate that facilities are continuing to experience significant benefits from the TURA program, while they also continue to face some challenges. These results provide a snapshot of the experience of Massachusetts facilities 20 years since the inception of the TURA program. They also provide baseline information that will be useful for later evaluations of the effects of statutory changes to TURA adopted in 2006 and implemented in subsequent years. The study also included a preliminary assessment of the experience of Massachusetts municipal agencies, community organizations, small business associations and others that receive assistance from the TURA program.     

The experiences of four corporate officials managing compliance with the Massachusetts Toxics Use Reduction Act

The Massachusetts Toxics Use Reduction Act (TURA), one of the original pollution prevention laws, has faced repeated repeal attempts and budget cuts. Yet the Massachusetts toxics use data and other analyses have provided firm indications that the law has actually worked. Though the program has survived it is notable that an approach that both saves money and reduces pollution has been reduced and not expanded. This paper does not attempt to answer the question of why the strategies of TURA have not seen wider application, but offers four stories to illustrate what happens when they are properly applied. The experience of corporate officials who had to comply with TURA, related at a symposium on the occasion of the law’s 20th anniversary, shed light on how a strong pollution prevention law can benefit regulated companies as well as the environment and worker and public health, and provide suggestions, in addition to data and surveys, that TURA-like sets of governance tools should receive wider consideration.     

How the Toxics Use Reduction Act continues to promote clean production Internationally

The Massachusetts’ Toxics Use Reduction Act (TURA) of 1989 set an important milestone in the roadmap to Clean Production. The Act’s focus on a clear definition, methodology, and mandatory planning requirements have proved successful in getting companies in Massachusetts to reduce their use of toxic chemicals in manufacturing processes. Such results are inspirational for government officials and advocacy groups attempting to reduce toxic emissions in their communities and set progressive chemicals use policies. This paper will summarize three initiatives where TURA was a catalyst and continues to impact international chemicals policy: the Sewer Use By-law in Toronto, Canada; the European Union’s REACH chemicals legislation and the international campaign by Greenpeace in Asia and Latin America to achieve zero discharge of hazardous substances into rivers. The example of Toronto and REACH show how one or more essential aspects of TURA were incorporated into legislation. In the case of REACH TURA’s requirement of mandatory planning became an important example and NGO demand during the formation of Europe’s new chemicals regulation and resulted in the first substitution assessment planning requirement in EU wide legislation. Work is now ongoing to promote TURA type legislation in Latin America and Asia. However the ability to transfer the TURA framework to regions with inadequate government oversight and cheap disposal costs is seriously hampered. Although NGO campaigns in Asian and Latin America advocate zero discharge of hazardous emissions through toxics use reduction and elimination, much training and accountability will be needed within government and companies to understand the benefits of toxics use reduction and actually implement all or parts of the TURA framework. The Toxics Use Reduction Act came into force in 1989 with high environmental awareness, an engaged citizenry and a responsive government entity. Perhaps these are the same conditions that must exist for its successful transference to industrializing countries.     

Primary prevention for worker health and safety: cleaner production and toxics use reduction in Massachusetts

Worker health and safety and environmental protection are not always considered simultaneously when attempting to reduce or eliminate hazardous materials from our environment. Cleaner Production-Pollution Prevention (CPPP), as primary prevention, has the ability to shift worker health and safety strategies from control to prevention, where exposure prevention precedes exposure control. This paper evaluates the effect of Cleaner Production-Pollution Prevention in the form of toxics use reduction (TUR) on worker health and safety at three printed wire board facilities covered under the Massachusetts Toxics Use Reduction Act. In-depth case study analysis, including an assessment of each facility’s health and safety status, explores the root causes of the worker health and safety changes attributable to the TUR interventions. By exploring the relationship between worker health and safety and environmental protection within the corporate structure; we can identify the factors driving companies to reduce toxics both inside and outside of their plants, as a single concern.While traditionally there have been divergent paths of practice for worker health and safety and environmental protection, the two are closely connected. It is important, however, to consider the implications of risk transfer/shifting between the general and work environment. In order to avoid this risk shifting, worker health and safety perspectives and goals must be more clearly incorporated into the Cleaner Production-Pollution Prevention/TUR management system. This study opens a dialog around the effects of environmental intervention programs on worker health and safety. We realize now that while CPPP/TUR reduces exposure to toxic substances in the general environment, it also offers unique opportunities to reaffirm primary prevention principles in the work environment.