Defining Toxics Use Reduction

What is toxics use reduction?

The Toxics Use Reduction Act was revolutionary in its focus on preventative strategies. The term toxics use reduction (TUR) refers to strategies which reduce, avoid or eliminate the use of toxic chemicals or the generation of toxic wastes, in the manufacturing process. TUR does not include the management or treatment of wastes once they are produced. For example, sending solvent waste to a chemical recycling facility for treatment may be a smart strategy, but it is not toxics use reduction because it does not reduce or eliminate the use of toxic chemicals at the source.

A key tenant of TUR is reducing risks to workers, consumers, and the environment, without compromising productivity and without shifting risks between groups.

TUR is a form of pollution prevention (P2), which are practices that reduce or eliminate the generation of any waste at the source. These strategies look upstream to identify actions that reduce the possibility of generating pollution and can also referred to as source reduction.

📋 TURA Definition: Toxics Use Reduction (310 CMR 50.10) 

“Toxics use reduction means in-plant changes in production processes or raw materials that reduce, avoid or eliminate the use of toxic or hazardous substances or generation of hazardous by-products per unit of production, so as to reduce overall risks to the health of workers, consumers or the environment without shifting risks between workers, consumers or parts of the environment…”

It is important to differentiate between pollution prevention (P2) and pollution control. Pollution control strategies deal with waste after it has been generated and include recycling, waste treatment, and energy recovery. For example:

  • Waste-to-energy processes which recover energy from the burning of solid waste are an example of pollution control.
  • Air scrubber installation to prevent release of particulates to the environment is an example of pollution control.
  • Chemical neutralization of hazardous waste as it leaves a facility is an example of pollution control.

While these actions are important, they are not examples of pollution prevention. They focus on mitigating and controlling the waste stream (e.g., solid waste, particulates, hazardous waste) after it has been created. Additionally, pollution control focuses on compliance with regulations. Once a facility meets the pertinent regulation, it may not feel motivated to pursue further action or continuous improvement.

Pollution Prevention vs. Pollution Control

In 1990, the Pollution Prevention Act helped develop a formal definition of pollution prevention and a strategy for making P2 a national priority. The strategy established a hierarchy to guide national policy.

  1. Ideally, pollution should be prevented or reduced at the source whenever feasible (source reduction).
  2. Pollution that cannot be prevented should be recycled in an environmentally safe manner whenever feasible.
  3. Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible.
  4. Finally, disposal or other release into the environment should be employed only as a last resort, and should be conducted in an environmentally safe manner.
It’s important to differentiate between pollution control and pollution prevention (P2) →
  • Pollution control includes treatment, recycling, waste reduction and minimization, and energy recovery (incinerating waste to generate heat or electricity). Any action taken after waste has been generated, including recycling, treatment, concentration, or dilution is not considered pollution prevention. 
  • Pollution prevention focuses on avoiding the generation of waste in the first place. It is about looking upstream to identify actions that reduce the possibility of generating pollution (also referred to as source reduction).

TUR planning helps one find opportunities to reduce the potential generation of hazardous byproducts (pollution) by changing feedstocks or processes, increasing operation efficiency or reassessing performance set points to reduce the amount of a toxic chemical required. These are just a few examples of pollution prevention activities.

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