Understanding the TURAData
Although reporting under TURA has been required in Massachusetts since 1990, figuring out how toxics use has changed since then is not a simple matter of adding up all the amounts reported. This is because there have been a number of changes in the reporting requirement. The result is that trying to add all the amounts together is like trying to add apples and oranges. This section describes how you can avoid the reporting equivalent of fruit cocktail.
TURA reporting varies from year to year for a number of reasons. These reasons are outlined below. As you will see, each reason introduces some variability into the TURA information. In order to calculate trends, you must understand these variables and take them into account. On the following page, we have provided examples that illustrate how each variable can be accounted for when reporting trends in toxics use in Massachusetts.
Here is the list of reasons why you need to be careful when adding reported quantities:
- Different types of facilities were added to the reporting requirement in different years. In 1990, only certain manufacturing companies were required to report use of toxic materials. Starting in 1991, both certain manufacturing and certain non-manufacturing companies were required to report. Reporting progress for companies that started reporting in different years is best done by reporting progress only over the years reported in common.
- Different chemicals were added to the reporting requirement in different years. Some chemicals have been required since reporting began in 1990. Additional chemicals were required starting in each of the years 1991, 1992, and 1993. This means that total quantities reported by a company may have risen from 1990 through 1993 simply because more chemicals were being reported, not because more chemicals were being used. Reporting progress for chemicals for which reporting was first required in different years is best done by reporting progress only over those years when the chemicals were all reported.
- Some chemicals or specific uses of chemical have been taken off the list of reportable chemicals. These chemicals are referred to as delisted chemicals. When a chemical is delisted, a company is no longer required to report it even if they continue to use it. However, the quantities of delisted chemicals reported prior to the delisting are still included in the TURA data. As a result, the total quantities reported by that company will be lower following delisting of a chemical, simply because the delisted chemicals are not included, not because the company reduced the amount of chemicals used.
- Companies move from one town to another. This means that when looking at totals for a community, the quantity of toxics used can go up or down not because of toxics use reduction, but instead because companies have moved in or out of the community.
- Facility identification numbers change. Companies are identified in the TURA data by a unique "Facility ID number." Occasionally that number will change, for example when a facility changes ownership or changes the nature of its business.
- Some companies claim reportable data as trade secret. In this case, although they still have to report the information, it is not included in the data presented here. Companies are allowed to claim reportable data as trade secret in order to protect proprietary manufacturing processes.
- Individual companies change the chemicals used, use less than the reportable quantity of a reportable chemical, or stop using TURA reportable chemicals altogether.
Because of these differences, it is not always possible to add the different quantities reported and come up with a meaningful picture of how toxics use in Massachusetts has changed since 1990. This is especially true when looking at toxics use on the level of an individual community or company.
The following sections show graphically how facility and chemical information has changed over the years that TURA information has been reported.
How Facility Information Has Changed
The Standard Industry Classification code, or SIC code as it is commonly called, is a four-digit number used to categorize companies according to the type of business they do:
- Companies with an SIC code between 2000 and 3999 are considered manufacturing facilities. These companies were first required to report under TURA in 1990.
- Companies with an SIC code less than 2000 or greater than 3999 are nonmanufacturing companies and they were first required to report under TURA in 1991.
The table below shows graphically the years that data is available for each of these two types of facilities.
Data Available by Type of Company
SIC Codes 2000-3999
SIC Codes < 2000 or > 3999
DA = Data available for this year
NR = Company not required to report in this year
How Chemical Information Has Changed
In addition to phasing in the types of facilities required to report, TURA regulations phased in the chemicals that companies were required to report. When TURA reporting began in 1990, companies were only required to report toxic chemcials if they were on what was called the EPCRA or TRI chemical list. (EPCRA is the federal Emergency Planning and Community Right-to-Know Act. It required that companies report on emission of certain chemicals. The data is kept in a federal data base called the Toxic Release Inventory, or TRI.)
From 1991 to 1993, additional chemicals were added to the list of TURA-required-reporting chemicals. Because this list of chemcials came from a federal law known as CERCLA, they are commonly referred to as the CERCLA list. Since a third of the CERCLA chemicals were added each year from 1991 to 1993, the chemicals were called the 1st Third, 2nd Third, and 3rd Third CERCLA chemicals.
The table below shows graphically the data that is available for these groups of chemicals.
Data Available by Chemical Reporting Group
|Original list of TRI Chemicals||DA||DA||DA||DA||DA||DA||DA||DA|
|CERCLA chemicals - 1st third||NR||DA||DA||DA||DA||DA||DA||DA|
|CERCLA chemicals - 2nd third||NR||NR||DA||DA||DA||DA||DA||DA|
|CERCLA chemicals - 3rd third||NR||NR||NR||DA||DA||DA||DA||DA|