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Understanding Trends in Toxics Use

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 as outlined below. Each reason introduces some variability into the TURA information. In order to calculate trends, you must understand these variables and take them into account. See examples of how to calculate trends 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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. Individual companies change the chemicals used, use less than the reportable quantity of a reportable chemical, or stop using TURA reportable chemicals altogether.