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TUR in MA:setting record straight

Setting the Record Straight on Toxics Use Reduction In Massachusetts
by Elizabeth Harriman andKen Geiser
The Massachusetts Toxics Use Reduction Institute

	December 18, 1997

The Chemical Manufacturers Association (CMA) has recently published a
report describing results from a study of materials accounting and toxics
use reduction (TUR) in New Jersey and Massachusetts.  In the opening
paragraphs of this report it is noted that this is a preliminary result of
a "continuing assessment".

While the CMA effort is appreciated, we would like to correct some
mis-conceptions in the report about use and byproduct reduction trends in
Massachusetts.  There are many factors influencing reported chemical
quantities, and their "brief examination of the results of the
Massachusetts Toxics Use Reduction Act" has failed to exclude confounding
factors such as changes in levels of production. The Massachusetts Toxics
Use Reduction Act (TURA) Program has devoted considerable effort to
developing, testing and implementing a coherent methodology for measuring
TUR progress.  That methodolgy is designed to present metrics that most
accurately monitor progress in a manner that meets the goals of the law.

CMA states that "plant closings have...played the dominant role in
reductions of chemical use."    This argument underscores the need to
adjust trends for changes in production levels.  Indeed, plant closings are
not the only economic story in Massachusetts.  There have also been plant
startups, increases in production at many existing facilities, and
transfers of production capacity among facilities within the state.  Thus,
in order to understand what chemical use and byproduct changes are
attributable to toxics use reduction, we must factor out, as best we can,
changes which are due to increases or decreases in production.

Each year the Massachusetts TUR program collects data from all of the 500
to 700 firms that report to the state and conducts a series of analyses on
this data.  In 1997, the state program reported a 20% decrease in toxic
chemical use and a 30% decrease in toxic chemical by-product for the period
1990 to 1995.  These data cover a core set of chemicals and industries and
are normalized against an economic indicator to reduce the confounding
effects of fluctuations in the state economy.  The indicator used for
economic normalization at each facility is the activity index reported by
these same facilities on the federal Toxics Release Inventory Form R.
During the period 1990 to 1995 this adjustment accounts for roughly a 15%
increase in aggregate state production.

The idea of adjusting for changes in production to produce indicators of
"relative reductions" appears to be supported by CMA and they quote the
Massachusetts results of a 20% reduction in toxic chemical use and a 30%
reduction in generation of toxic chemical byproduct.  Yet, CMA states that
plant closings have played the dominant role in reductions of chemical use
in Massachusetts.  The report points to data from just three facilities to
account for these reductions.  
The logical way to test this theory is to examine only those facilities
which have reported in all the years 1990 to 1995.  This will eliminate
confounding factors such as plant closings as well as new plant startups
where reported production ratios may not accurately account for changes in
production.  However, this method will understate TUR progress by excluding
from the analysis all those facilities which have fallen below threshold by
successfully implementing TUR.  This consistent set of facilities from 1990
to 1995 reports a 20% increase in production, which is actually 5% higher
than the level of economic performance for the conventional universe.
Adjusting actual changes for the 20% increase in production reveals a 12%
reduction in toxic chemical use and a 29% reduction in byproduct generation
from 1990 to 1995.  

Therefore, looking at Massachusetts TURA filers in a way which we know
understates progress but factors out all plant closings and plant
start-ups, we still see significant reductions in toxic chemical use and
the generation of toxic chemical byproducts.

We urge that in future reports the CMA try, as we have, to normalize data
in a way that most accurately accounts for the changes in chemical use and
by-product and does not confuse changes in economic factors with changes in
TUR performance.

Janet Clark
Technology Transfer Manager
MA Toxics Use Reduction Institute
University of Massachusetts
One University Ave.
Lowell, MA  01854-2866
Tel 978-934-3346
Fax 978-934-3050
email clarkjan@turi.org

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