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From:	"rick reibstein", INTERNET:Rick.Reibstein@state.ma.us
TO:	(unknown), wweinstein
DATE:	16/12/1997 4:38 PM

RE:	CMA Study


CMA claims plant closings account for progress in Massachusetts.  Besides the 
materials accounting article, in an Oct. 13 letter to Chemical and 
Engineering News, they cite three companies that had plant closings, and 
state that they account for 116 million pounds of toxics use.

A closer examination shows that even adjusting for the three plant closings, 
MA has had substantial progress in both use and waste reduction.

We have had economic growth in the state.  Our unemployment is way down, our 
tax receipts are way up, and our shipments from all SIC codes covered under 
the act are substantially higher.  Form R activity indices show a 15% 
increase in production.  In 1990 we had 876 million pounds of use.  A 15% 
increase in production should have resulted in 1 billion 6 million pounds of 
use.  Instead, we had total usage of 805 million.  There's 201 million pounds 
missing.  Clearly, the 116 million from plant closings cannot account for the 
entire reduction.  

In addition, although the Novacor Leominster plant eliminated tens of 
millions of pounds by closing, the Novacor Springfield plant picked up 
production considerably.  It appears that production may have been shifted to 
another location - that is not really a plant closing.  Correcting for this 
results in 73 million pounds from plant closings, not 116.  What we're left 
with is either 128 million pounds or 85 million pounds apparently due to 
TOXICS USE REDUCTION.

Compared to 1990 figures, this is either a 14.6% or a 9.7% reduction in use.  
Compared to the expected toxics use from increased production, it is either a 
12.7% or an 8.4% reduction.  Any way you look at it, it is a significant 
reduction.
                                           
Taking out the waste byproduct from these plant closings affects our waste 
reductions hardly at all.  From our actual reduction of 21 we have to 
subtract about 3 million due to plant closings.  We would have expected to 
have 124 million pounds in 1995, compared to 108 in 1990, and instead had 87 
million pounds in 1995.  Thirty four million pounds reduced is 31.5% of 1990 
figures, 27.4% of 1995's expected byproduct generation.                       
                
This can be compared with the national trend of increased waste generation, 
as indicated by TRI section 8.  EPA's estimate is that production-related 
waste has increased 6.8% from 1991 to 1995.  

Massachusetts TURA's critics have in the past stated that Connecticut has 
achieved similar release reductions without a TUR program.  Firstly, that 
sells short the achievements of CONTAP (the demise of which we are still 
mourning!)  Secondly, it ignores the reductions in use and waste which we 
have had in MA.  I do not know what has happened in CT concerning use and 
waste.    

Another indicator of progress in Massachusetts is apparent when you put 
together the use and waste figures.  This gives you a rough chemical use 
efficiency.  In 1990, 12.5% of covered chemicals used by the categories of 
companies covered by the act ended up as waste, what we call byproduct - 
whether lost to air, water, or shipped out in drum.  In 1995 the ratio was 
10.8%. If companies had continued to generate waste byproduct at the same 
rate in 1995 as they had in 1990, that same 805 million pounds of chemicals 
used in 1995 would have resulted in 100.6 million pounds of waste, instead of 
87 million. 

Measuring chemical use efficiency is a way of looking at progress that does 
not require normalization for production.  No matter what plants closed or 
production occurred, the chemical use efficiency measure tells you how much 
waste was generated relative to whatever amount of chemicals was used.  It 
does not tell you how much you have avoided due to companies dropping below 
thresholds.  It shows how much can be achieved even when companies cannot 
substitute other input materials - thirteen million pounds of use was reduced 
just from using the chemicals more carefully.