Toxics Use Reduction Planning - The Fate of Pollution Prevention in Massachusetts' Metal Finishing Industry
Ruta Kshirsagar
Fourteen states have passed Pollution Prevention (P2) legislation to reduce
the risk of using toxic chemicals. In 1989 Massachusetts passed the Toxics Use
Reduction Act (TURA), which requires large quantity toxics users to document
how they will achieve pollution prevention. The idea is that by complying with
the planning laws companies will be forced to learn about their toxics use and
will initiate pollution prevention activities.
This study employed an impact assessment to determine whether the planning process encouraged the metal finishing industry in MA to consider P2. Key personnel at three environmental agencies (MA Department of Environmental Protection, Office of Technical Assistance, & the Toxics Use Reduction Institute) were interviewed to obtain perspectives on how the TURA program is supposed to work. Finally, a TUR Plan review, company interview, and facility tour were conducted to evaluate the implementation and management of the TURA Program from the industry's perspective.
Eight metal finishing companies were selected based (in part) on geographic region, company size, and willingness to participate. Each company's TUR Plan was reviewed for the required elements and each company representative was asked which factors of TUR planning did and did not motivate them. Finally, each company's facility was toured to observe their general housekeeping and TUR practices.
Although some aspects of TUR planning were found to be tedious and/or time-consuming, the overall planning process received high ratings. All eight companies made a good faith effort to identify and evaluate opportunities to reduce pollution at its source. While companies saw the rewards of planning, it was not solely TUR planning that encouraged them to consider and/or implement P2. The prospects of cost savings, having strong upper management support, and receiving technical assistance also encouraged these companies to consider TUR.
The most commonly cited barriers to TUR planning were the "Cost-of-Toxics"
section of the TUR Plan and the extensive calculations required throughout the
planning process. Companies requested more state agency outreach in the form
of case studies and technical assistance seminars/workshops. Two major recommendations
from this study are to decrease calculation requirements and increase outreach.