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What are companies required to report?

Companies that report the use of a toxic material are required to report how much of the toxic is used in all the different processes at the company. From the point of view of TURA reporting, companies report the use of toxics in two broad categories: how the toxic material is used, and what happens to it after it is used.

Terms That Describe How a Toxic Chemical is Used

There are three different types of uses: manufactured, processed and otherwise used. Together, these types of uses add up to total use.


Manufactured means to produce, prepare, import or compound a toxic or hazardous substance. Note: This definition includes the "coincidental" manufacture of a substance during manufacturing, waste treatment or fuel combustion.


Processed means the preparation of a toxic or hazardous substance, including, without limitation, a toxic substance contained in a mixture or trade name product, after its manufacture, for distribution in commerce:

  1. in the same form or physical state, or in a different form or physical state from, that in which it was received by the toxics user so preparing such a substance; or
  2. as part of an article containing the toxic or hazardous substance.

Note: repackaging the chemical is considered processing it.

Otherwise Used

Otherwise Used means any use of a toxic substance that is not covered by the terms 'manufacture' or 'process' and includes use of a toxic substance contained in a mixture or trade name product. Relabeling or redistributing a container of a toxic substance where no repackaging of the toxic substance occurs does not constitute use or processing of the toxic substance.

Total Use

Total Use is the amount of the chemical either manufactured, processed or otherwise used at a facility, in other words, the sum total of the three uses listed above.

Terms That Describe What Happens to a Toxic Chemical

Once a toxic chemical is used, something happens to it. It either becomes a byproduct or it is shipped either as a product or as part of a product. These two results are called generated as byproduct and shipped in product.

Byproduct is further broken down into transfers and releases. These terms reflect the fact that some of the toxic material may leave the facilities, for example as a solid or liquid waste that is carted away from the site (a transfer), or as an air emission (a release). Quantities for transfers are not shown in the reports.

Generated Byproduct

Generated Byproduct means all nonproduct outputs of toxic or hazardous substances generated by a production unit, prior to handling, transfer, treatment or release.

Shipped in Product

Shipped in Product means any toxic or hazardous substances that leave the facility as product or as part of an article containing the toxic or hazardous substance.


A Release is a discharge of a toxic chemical to the environment. This includes releases to the air, either as a stack or fugitive emission, discharges to bodies of water such as streams or lakes, or discharges to the ground or underground.

One question that is frequently asked about the TURA data is why the amount of byproduct generated, the amount shipped in product and the amount released don't all add up to the total amount used. Here is one reason: In some cases, the toxic is transformed in the process and becomes something that is not hazardous. In this case, the company is no longer required to track and report the quantity.