Taking Carcinogens out of the Workplace
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A discussion of how the Massachusetts Toxics Use Reduction Act is a model of how to proactively reduce the use of carcinogens in business
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Taking Carcinogens out of the Workplace
- 1. Taking Carcinogens Out of the Workplace: A win-win for workers and industry in Massachusetts kNOw cancer in the workplace December 10, 2009 Australian National University, Canberra
- 5. Toxics in the Workplace
- 9. TURA Data on the Internet
- 12. TUR Program Structure Toxics Use Reduction Institute Office of Technical Assistance Department of Environmental Protection Administrative Council
- 13. Use … DOWN 40%
- 14. Byproduct … DOWN 70%
- 15. Emissions … DOWN 90%
- 16. Shipped in Product … DOWN 60%
- 20. Carcinogens 30%
- 34. TURI’s Five Chemicals Alternatives Assessment Study
- 37. Table 7.4.2 C: Summary of Plasticizer Alternatives Assessment for Medical Devices Key Assessment Criteria DEHP (Reference) Comparison Relative to DEHP TOTM DEHA BTHC DINCH DINP
- 38. Table 7.4.2 J: Materials Alternatives Assessment Summary for Medical Devices
- 39. Table 7.4.2 J: Materials Alternatives Assessment Summary for Medical Devices Key Assessment Criteria DEHP/PVC Reference Comparison of Materials to DEHP/PVC EVA Polyolefin Glass Silicone TPU
- 40. “ Choosing safer alternatives will not only help prevent widespread suffering, it will reduce the burden on our economy by averting high health care and special education costs as well as lost productivity.” -Alliance for a Healthy Tomorrow
- 41. Contact Us!
- 42. Massachusetts Toxics Use Reduction Institute www.turi.org 978-932-3275 University of Massachusetts Lowell 1 University Avenue, Lowell, MA 01854 www.uml.edu Pam Eliason, [email_address] 978-934-3142
Editor's Notes
- Thank organizers for making it possible for me to be here Knee surgery Good news … won’t get lost in the bush Bad news … can’t see as much of this beautiful land as I’d like But what I have seen is absolutely breathtaking
- Let me just say that it’s all a bit confusing. I have no idea where here is. But I do know that there should be a sign for Lowell Massachusetts (near Boston), which would be about
- 16,930 km thatta way So why am I here? Regulations in place … OSHA, etc. … but workers still exposed to carcinogens. ACS and other cancer organizations tend to focus on issues like smoking and obesity when they talk about preventing cancer Massachusetts has been focused on helping companies and communities throughout the state reduce the use of exposures to make Mass a safer place to live and work. How did this all come about?
- From the American Cancer Society's perspective on environmental cancer. http://caonline.amcancersoc.org/cgi/content/full/caac.20041v1 "...In contrast to the broad definition of environmentally related causes of cancer used by the ACS and most other public health agencies, some members of the general public and scientific community use the term "environmental" to refer more specifically to toxic chemicals, environmental pollutants, radioactive exposures, and other predominantly manmade hazards that people encounter, often involuntarily, in their daily life. These exposures may occur from consumer products; old or new building materials; additives or contaminants in food or drinking water; and pollutants in indoor air, urban environments, and larger ecosystems. The exposure levels to the general public are typically orders of magnitude lower than those experienced historically in occupational or other settings in which cancer risks have been demonstrated. The resulting cancer risks are generally so low that they cannot be measured directly." Note Lin Fritschi’s work estimating 10% of cancer in Australia associated with occupational exposures to chemicals. The bottom line is that we should be using precaution when considering the use of carcinogens
- With your neighbors, discuss how YOU would address the issue of toxic chemical use in the workplace … History of the making of TURA Advocates say ban chemicals Industry says let us site a hazardous waste facility in Massachusetts Group, led by Ken Geiser then of Tufts Univ gathered group together to negotiate Incorporate planning into law, with no mandate to Industry and NGOs see this as a good compromise … companies find value in the planning process, and toxics use is indeed reduced The program has focused on some 190 chemicals and involved over 1000 firms Carcinogens were NOT our focus
- The program has focused on some 190 chemicals and involved over 1000 firms Carcinogens were NOT our focus So, what do I mean when I say toxics use reduction or TUR? TUR is pollution prevention that emphasizes source reduction over control of pollution The guidance established in the Act and taught to over 1000 certified TUR planners over the course of the Program’s history focuses on six methods – direct and indirect TUR techniques TURA combines occupational exposure into process … not seen elsewhere
- Emphasize use here
- Annual reports submitted by about 600 facilities Companies who reports include those that: Use a listed toxic chemical (approximately 1500 chemicals) over reporting threshold amount. This threshold is typically 10,000 pounds/year, but is lower for specific highly toxic chemicals (e.g., PBTs) Employ 10 or more FTE Are within specified SIC codes (primarily manufacturing). Go to http://turadata.turi.org/report.php?action=report_sic_home to see the industry sectors covered. So what do these companies have to report on? Annual use Annual generation of byproduct Amount shipped in product annually Production index – used to normalize data to facilitate evaluation of trends statewide Works alongside US EPA emissions inventory reporting (TRI) to provide comprehensive picture of what is happening in our state with respect to the use and emission of chemicals.
- Data available on the web at www.turi.org/turadata Data is displayed by year, categorized by: Chemical Facility Community This is a very valuable resource for companies, environmental advocates, researchers and people from outside of Massachusetts who are interested in delving into more detail about the activities of TUR reporting companies over the course of the program. Currently the data is only updated to reporting year 2004 (2005 is going through some final quality control and will be available in June 2008). The delay in data is due to the submission 6 months after the close of the reporting year coupled with a lengthy QA/QC process that is further bogged down by limited resources (people, $$ and upper management prioritization) at DEP. Note the third bullet: 47 carcinogens associated with TURA reportable chemical list Other groups include reproductive toxins, organochlorinated solvents, metals, common solvents
- This is the typical process that companies subject to TURA undergo. The dark blue ovals represent the point where the TUR Planners operate. It is up the company to determine what it will implement and to measure how successful it’s actions have been Planning process done with teams within the company Must consider occupational environment as options are evaluated – cannot shift risks Encourages companies to consider why they do what they do and how they can do it more efficiently – leads to a more competitive and sustainable business model
- Examples: Direct: Substitution: Solvent substitution in washing and degreasing Cyanide replacement in electroplating baths Product Redesign: Hydrocarbon-based inks replaced with water-based inks Indirect : Process modification: Dry-process coatings replacing wet-process coatings O&M: Installing energy- and water-conserving pumps and motors Installing automated pressure and temperature controls to reduce leaks and spills Chemical inventory control In-Process Recycling: hard-piped return of process by-product as make-up for process solution – no releases possible.
- Administrative counci l includes leaders from major public health, environmental and labor agencies of state – provide guidance and decisions on implementation of the act. TURI: part of the university system. Research and training from TURI supports growth in TUR Work with industry to research new alternatives and processes Demonstrate innovative technologies peers are implementing Provide training on innovations and impact of policy changes Analyze efficacy of program and recommend policy to legislators Work with grass roots organizations to implement TUR at the community level OTA and DEP part of the Office of Environment and Energy Agency OTA : On-site confidential technical assistance from OTA disseminates technology innovations and gets feedback on industry needs. OTA works with smaller companies who might otherwise not have the resources to take advantage of what is learned by their larger peers during the TUR planning process. DEP: Compliance enforcement from DEP assures that progress does not slow. DEP is responsible for receiving, checking for quality and consistency, and making public the data from companies.
- These numbers are adjusted for production These numbers only for “core” companies – i.e., those who were reporting in 1990 and were still reporting in 2005. About 100 companies Trend flattens out after 1998 Currently about 450M pounds of toxic chemicals used annually
- Trend flattens out around 2001 Currently around 24M pounds of byproduct generated annually 1990 = 100Mpounds 2007 =
- Even more dramatic reductions in amounts released to air, water or solid waste off site Release data derived from TRI database (industry not required to report releases to TURA – remember that our goal focused on use reduction and haz waste minimization So these are the overall numbers … but what about carcinogens
- Here is a quick look at what firms have achieved under this program. Vicor Corporation Manufacture power converters and sources for high tech electronics applications Electronics industry had been powerhouse in Mass, but has largely disappeared over the years with outsourcing Impacted by global restrictions Redesigned product to eliminate lead from all but exempt products and significantly reduce exposures for employees LIGHTOLIER MAKES: Lamps, fabricated metal, metal finishing Used TUR techniques to identify energy and water conservation opportunities Savings associated with the results of the TUR planning process VH BLACKINGTON MAKES badges, service pins TCE cleaning operations were replaced with an aqueous cleaning system using s imple green crystal cleaner. Changes made to the company bright dip operations reduced the copper and zinc loading to the wastewater by 85 percent. These changes include chemistry, metal recovery, improved process management, and the installation of drag-out tanks and a closed-loop system for rinsing operations. Switched from a 2-stage to a single stage cyanide desmut of sodium hypochlorite (bleach)
- INNER TITE: Manufacturer meter locking devices, meter seals and a host of mechanical accessories sold exclusively to utility companies TUR Technique: replaced its existing parts degreasing equipment with two entirely enclosed degreasing units. Ceramics Process Systems Small company that makes Faced with regulatory action, brought in TURI lab to identify options Significant process modification lead to safer working environment, elimination of reporting requirements and significant reduction in operating expenses associated with hazardous chemical handling and waste management IntelliCoat Provide specialty coatings for textiles Went from solvent-based system to powder-based system
- There are quite a few that are reported by companies in Massachusetts Styrene by far the highest volume But a whole host of others, from heavy metals to solvents to sulfuric acid Does this resemble the picture in Australia?
- Data overwhelmingly dominated by one chemical (styrene monomer) used primarily by one company Styrene … TURI/TURA program studied it early on because so overwhelming with respect to all other chemicals used. Basic TUR led to reductions in early years. The company did the TUR planning and implementation without much interaction from the program.
- These figures (following) show raw numbers … overall impact on the state (rather than production adjusted) Zero Cd reported in 2007 Lead increased due to change in reporting status … as a PBT now has lower reporting threshold (100 lb) Specific focus on TCE has helped in reducing use for what is often considered a low tech necessity for smaller companies Perc and formaldehyde reductions largely due purely to the act of planning … companies saw the savings and value in reducing the use of these carcinogens in their work places.
- Explaining Lead: Lead byproduct numbers associated with removal of a provisional exemption by DEP for waste combusters. DEP previously had a special policy for Municipal Solid Waste Combusters (MWC) that exempted them from certain chemicals even though they were a covered SIC code because they were too hard to calculate (Pb in trash to be incinerated). For 2003, 137 facilities reported the use of lead and 115 reported the use of lead compounds. The largest use of lead was reported by MWCs (2,642,987 pounds or 79% of total lead use), due to lead in the trash that MWCs combust. Nearly 100% of this lead becomes chemically and physically bound in ash that is disposed in lined on-site or off-site landfills. (Note that of the 819,467 pounds of on-site releases of lead, 818,534 pounds were in ash and 933 pounds (1% of Pb entering MWC) were released as air emissions.) The 1,823,519 pounds of lead reported as transferred off site was in ash disposed in off-site landfills. The second largest use was in the fabricated metals sector (363,406 pounds or 11% of the total reported use), where the metal is used to create cans, drums, plumbing fixtures and other metal objects. The electronic equipment industry (i.e., printed circuit boards, semiconductors) represented the largest number of filers (37) as a distinct group. This sector reported a total use of 119,651 pounds or 4% of the total reported. Typically, facilities in this sector use lead in soldering operations.
- Pb use increased by 3%. inc in use at PBT policy minimal because small amount (>100 pounds) now reportable, versus previous amount of 25,000 pounds. Municipal combuster exemption removal in 2003 shows another spike in use by trend now going down again. (but of course, that amount was always there, just not reported) But what we see here is a vastly improved occupational environment for the manufacturing workers in Massachusetts
- Again … Dramatically improved occupational environment for workers in Massachusetts as they are exposed to significantly lower fugitive air emissions of these carcinogens.
- This is just a sample of the more commonly used carcinogens in Mass
- TURI’s Lab Helps Small Companies Switch Lab focuses on efficacy of safer alternatives, which is a vital piece of information needed before companies can commit to the switch Developed to address common problem facing industry … what methods to use to provide clean components as they manufacture their products. Research results from lab are applicable across industry sectors “… we were able to successfully reduce the TCE and PCE use for the small number of companies that were identified. This demonstrates that the provision of direct, free, and highly competent technical assistance can have a significant effect on a company’s toxic chemical use. The combination of OTA’s technical assistance expertise and TURI’s ability to test alternatives in the SSL was crucial to the success of this project.” >177,000 lb … 67% reduction since 1993
- The scientists at TURI’s Laboratory have tested over 1900 alternative/substrate/contaminant combinations. The database provides in depth detail about the alternatives tested, and the results. The goal is to assist companies in finding effective yet safer alternatives to their current cleaning processes. Companies send real examples of their products/pieces that need to be cleaned, and TURI’s scientists conduct trials to evaluate viable safer alternatives. This is an important resource for companies in Massachusetts who have specific cleaning needs: e.g., currently using TCE on stainless steal to remove buffing/polishing compounds. The example on this screen shot shows a number of trials conducted by our scientists in the Laboratory at TURI, which have yielded several effective and safer alternatives. To learn more about how the alternatives are rated (i.e., the “safety score”), and to find more tested alternatives for a variety of solvents used on various substrate for specific contaminants, go to www.cleanersolutions.org. Or call the Laboratory Director, Jason Marshall, at 978-934-3133 or email at jason@turi.org.
- Matching grants promote conversion from perc to dedicated/100% wet cleaning Dry cleaners now looking at being caught under TURA with reduced reporting threshold (1000 lb) Example of need for technical assistance plus financial incentives to encourage adoption of safer alternatives by low margin companies in difficult economic times. Does Australia use wet cleaning rather than dry cleaning?
- It’s been a success! Workers are exposed to significantly lower levels of carcinogens in their working environment. Companies are facing significantly lower costs and liabilities. The Commonwealth of Massachusetts is indeed a safer place to live and work as a result! Economic and environmental quality can be improved But there are lessons that have been learned over our 20 year history that can be applied, and are being applied, to other countries and governments who want to manage the use of chemicals in the work place and protect the public health
- Balance mandatory and voluntary instruments (“sticks” and “carrots”) Goals need to be clear and ambitious Good metrics are needed to measure progress and enhance accountability
- Working with industry alongside advocates is powerful and productive Focus on facility planning and chemicals management is effective Smaller firms need technical assistance Reporting is complicated … having someone available to do follow up. Training and refresher training is important Technical assistance is needed to promote the adoption of safer chemical and technology alternatives – especially for smaller companies
- Companies find value in adopting safer alternatives when they do planning … but providing incentives, such as demonstrations of successful innovations, matching grants to encourage changes, and research funding to find Especially for smaller companies, awareness of looming changes in global market may not be on their radar … this is a service we provide Key sectors have been missed (i.e., health care and universities) Be prepared to evaluate the effectiveness of the program periodically and adjust to needs of industry
- As a result of industry request for more flexibility (after 15 years of TUR planning, most companies could demonstrate that their improvements had diminished and it was now becoming only a paperwork exercise). RC and EMS as alternatives to TUR planning High Hazard Substances (HHS). Cd, Cd compounds and TCE designated as HHS in 2008, first reports due in 2009. Perchloroethylene designated in 2009. Reporting threshold for HHS is 1,000 pounds/year. Fee currently is not changing, but considering an increased per-chemical fee for near future Lower Hazard Substances (LHS). Several chemicals designated as LHS in 2008. Still need to report on use, but no longer have a per-chemical fee for that chemical (company must still submit base fee - based on # of employees)
- How were they chosen? The Alliance for a Healthy Tomorrow (AHT), a coalition of environmental, labor and public health advocacy organizations, identified 10 chemicals they wanted the legislature to phase out. These included carcinogens, PBTs, reproductive toxins, chemicals of particular concern to constituents (i.e., chromium and formaldehyde used in construction materials, phthalates in baby products, etc). Some chemicals were priorities for certain members of coalition. There was no real definitive set of criteria/ not systematic. 10 chemicals: penta BDE, dioxin, TCE, 2,4 D, organophosphate pesticides and the 5 chemicals studied Legislature chose 5 of the 10 based partly on TURI’s recommendation (at their request) – which also considered availability of alternatives and global influences on use of chemical – things we could do something meaningful with given limited time/budget
- Drawer sanitizers that use formaldehyde – completely unnecessary function Trivalent chromium for hexavalent chromium Wet cleaning instead of Perc dry cleaning Cork flooring instead of vinyl flooring Soy based binders for building products
- Here is an example of what the results of our objective evaluation of alternatives resulted in. Note elements of criteria (technical/performance, financial, environmental and human health) Many parameters associated with technical requirements – this is typical because it is important to be able to demonstrate that the alternatives are usable EH&S criteria focused on issues of particular concern for chemical and application – e.g,. Ecotoxicity if there is a likelihood of chemical entering wastewater, worker exposure routes (inhalation) if it is likely to be present in breathing zone, etc. The results are present relative to the chemical being focused on (in this case, formaldehyde). Hence + for better, = for similar, - for worse, and ? if not enough information available to make even this level of qualitative evaluation.
- Note life cycle thinking elements
- New bill focuses on products and on substitution AHT sees it as a new model for protecting workers while promoting competitive advantage of business For priority toxic chemicals, the steps to the substitution program would be: 1. For each use of the priority chemicals, TURI conducts a study to determine whether there are one or more feasible safer alternatives. 2. Chemical Action Plans, prepared by state agencies, establish state-wide priorities for substitution based on the exposure danger of each chemical and how easily the chemical can be replaced. 3. The (DEP) sets deadlines by which companies must implement safer alternatives, based on state priorities. The deadlines will take into account the costs of the transition and the availability of assistance for substitution. 4. Businesses and other users make their own substitution plans and choices and can apply for waivers if safer alternatives are not technically or economically feasible. 5. The Business Transition Assistance Program helps businesses switch to the safer alternative. The program includes technical assistance, grants and loans, and research and development assistance. It is supported by funds raised through fees on toxic chemicals.
- TURI and LCSP