What is Toxic Use Reduction?

Toxic Use Reduction is a systematic process that helps companies reduce toxic chemical use at the source rather than managing or treating the waste - making workplaces safe for workers, communities and the environment. It means reducing toxic chemicals even if their use complies with legal limits, standards and legislation. Most chemicals and hazardous substances still cause harm to workers, members of the public and the environment at any set limit.

At its simplest, this can be reducing the number and amount of toxic substances used at work via COSHH, risk assessment and a determination to reduce workers and public exposure, reduce waste and pollution and contribution to climate change.

In manufacturing workplaces it means changing processes and systems and the chemicals used not based on individual risk assessment but on the eliminating whole classes of chemicals based on their hazards and making safer substitutions.

TOXICS USE REDUCTION ACT (TURA)

Adopted in 1989, TURA is designed to protect public health and the environment while enhancing the competitiveness of Massachusetts businesses.

Under TURA, facilities that use large amounts of toxic chemicals are required to report on their chemical use, conduct toxics use reduction planning every two years, and pay a fee. The fees paid by TURA filers support the work of the TURA implementing agencies, and are used to provide a wide variety of services, including training, grant programs and technical assistance.

Read the full text of the Act.

The Toxics Use Reduction Institute (TURI) provides education and training for companies; sponsors research into the development of cleaner, safer materials and technologies; provides grants to companies, community organizations, and municipalities; convenes business working groups to address specific environmental challenges; conducts policy research and analysis; and provides laboratory and library services.

Goals of the Massachesetts TUR 1989

achieve 50% reduction in byproduct (waste) by 1998 through required company plans
establish toxics use reduction as the preferred means of compliance
assist local employers
reduce the production and use of toxic chemicals

Results

Between 1990 and 2016, companies in Massachusetts reduced toxic chemical use by 66%, by-product production by 72% and onsite releases by 92%. 1400 chemicals now covered by reporting requirement.

HOW COMPANIES USE TOXICS

Toxics are used and toxic byproducts are generated in companies in two different areas: in manufacturing and in ancillary activities.

For manufacturing, a toxic material may be an input to a manufacturing process, such as a solvent used as one ingredient of the paint that a company sells, or a toxic many be created as a result of the manufacturing process, such as two chemicals mixed together to create a third chemical which is then sold by the company.

Ancillary activities are activities that go on at a company that are not directly part of the manufacturing process. For example, a company that makes metal parts might use a solvent to clean a machine between uses. The solvent is not really part of the manufacturing process, rather it is part of an ancillary activity. The picture below shows this graphically.

Toxics Use - An Example

One example of the use of toxics in manufacturing would be the creation of a silver-plated platter. A company might begin with the pre-formed base metal parts, in this case copper platters.

First the copper parts are immersed in a sulfuric acid bath to prepare the surface of the platters to receive the silver. The sulfuric acid does not become part of the final product, so it is called otherwise used. When the sulfuric acid is discarded it would be called byproduct because it does not become part of the product.
Next the platters are immersed in a silver plating bath. Both the copper and the silver are processed. The end result of the process is a silver-plated platter (with copper under the silver plate).
Most of the copper and silver that is processed becomes part of the final product and is called shipped in product.
A little of the copper and silver ends up either in the sulfuric acid bath or in the silver-plating bath and is called byproduct.
The company may consider the equipment and materials that are use used in this process as one production unit, with a description of 'prepare and plate silver-platters' or the company may consider it two different production units, with descriptions of 'prepare parts to be plated' and 'plate parts.'
The end result of the manufacturing process, the silver-plated platter, is called the product.

When you look at the community, company and chemical reports that show quantities of toxics, you will see the quantities reported using these same categories: processed, otherwise used, byproduct, and shipped. Other categories that you will see are manufactured and released. You will also see reports that list production units, along with a description of the process each uses and the product(s) each produces.

Case study - Mossmorran fife: ExxonMobil and Shell: what could and should be possible using ambitious TUR in Scotland to avoid impacts in countries like Nigeria?

ExxonMobil's Ethylene Cricker Planct supplies chemicals for plastics. Shell's plant separates gas and associated liquids taken from under the North Sea into propane, butane and natural gasoline and supplies ethane to ExxonMobil. Both with big carbon footprints, community impacts and questions about air pollution.

Actions Needed?

cut plastics use, recycle etc plus TUR - Green chemistry researchers identified bio-based alternatives to oil and gas based ethylene for plastics *polyhydroxyalkanoates, polymerise by fermenting glucose, modify starch and cellulose)
ExxonMobil and Shell effectively ignored green chemistry solutions over the decades. They are not present in the Scottish Government initiative, Industrial Biotechnology Innovation Centre, started in 2014 that looks for plant based alternatives to fossil fuels. Ineos had an agreement in 2015 to supply ExxonMobil and Shell with US shale gas for the ethylene plant
Scottish Government to move from warm words and blahblahblah to phase out these industries with rapid Just Transition and stop equivocating on the Cambo oil field and the Scottish oil industry. No half measures will work.

Unfortunately the UK does't have specific TUR leglislation:

4 Action points - local, national and international - protect the planet, protect communities and protect Workers by:

Applying TUR now at workplaces and in legislation. No need to delay
Using TUR strategies in Scotland and beyond with better monitoring, exposure standards and regulation/inspection operate along with empowered trade unions and community input
Use precautionary upstream principles on toxics that affect workers, communities and climate
Draw on green engineering, green construction and building and green chemistry in TUR

In addition:

More information on sources for safe substitution from Prof. A.Watterson presentation: “TOXICS” USE/ENVIRONMENT REDUCTION WORKSHOP (gmhazards.org.uk)

There is a lot that workers and their trade unions can do to reduce the toxins that workers are exposed to:

Use COSHH and ask your employer to carry out a COSHH assessment
Monitor air pollution and publish results from different parts of your workplace
Many unions have policies on Zero carbon, plastic and air pollution, and recycling but so too do local authorities and Governments across the UK - find them out and check that your employer is abiding by them and contributing to them
Work with employers to agree Green/Environmental Reps and if they wont, appoint them as health and safety reps and then provide them with an environmental/green brief - see Wales Green reps toolkit
Safety Reps have legal rights to be consulted on all things health, safety and welfare, to inspect the workplace and to investigate incidents, injuries and harm. Safety Reps and Safety Committee Regulation SRSC so use the legislation to be consulted on broader health issues

BrownBook2015.pdf (tuc.org.uk)

Do body mapping, hazards mapping and workplace mapping to identify where workers are being harmed and how:

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