Toxic Use and Hazardous Waste Reduction
The intent of toxic use and hazardous waste reduction (TUHWR) planning is to encourage businesses to reduce their use of toxic substances and/or their generation of hazardous waste, whenever technically and economically practicable, and without shifting risks from one part of a process, environmental medium, or product, to another. In order to achieve the stated goals, Vermont Statute: 10 V.S.A. Chapter 159 Sections 6623-6633 requires facilities that meet specific criteria to develop a plan for reducing toxic use and/or hazardous waste generation. The implementation of these plans is not required by statute. However, the planning process itself is intended to provide facilities with a summary of their toxics use and hazardous waste generation and serves as an opportunity to consider alternative approaches that might result in reductions.
The specific goals of planning are to:
- eliminate or reduce the use of hazardous, particularly toxic, materials, wherever feasible;
- reduce the generation of hazardous waste;
- reduce the release of chemical contaminants into the environment that have adverse and serious health or environmental effects; and
- document hazardous waste reduction and toxics use reduction information and make that information available to state and local government and the public.
Who Needs to Plan?
The statute requires businesses that generate greater than 2,640 pounds per year of hazardous waste, and/or manufacturers (SIC Codes 20-39) that use 1,000 pounds or more per year of certain chemicals (EPA Toxic Release Inventory listed chemicals, see SARA Title III, Section 313 ), to prepare plans to reduce the generation and/or use of these materials.
The Planning Process
The purpose of toxic use and hazardous waste reduction planning is to identify opportunities to reduce or eliminate the use of toxic chemicals and the generation of hazardous waste at the source rather than treating or controlling these materials after they have been created or used.
A series of worksheets with instructions to assist businesses have been created to assist with developing a plan. Businesses that are subject to planning must also file an Annual Progress Report. Copies of both the Toxic Use and Hazardous Waste Planning Guidance, which includes the worksheets that make up a plan, and Annual Progress Reporting forms, can be downloaded below.
- $400 per toxic chemical.
- $400 per hazardous waste stream.
- Up to a maximum amount of:
- $2,000 per plan for Class A generators.
- $400 per plan for Class B generators.
- $2,000 per plan for large users.
- $4,000 per plan for Class A generators that are large users.
- $1,200 per plan for Class B generators that are large users.
Annual Progress Report Forms (due annually by March 31):
- Download Annual Progress Report Form - PDF format, to print and fill out
- Download Annual Progress Report Form - MS Word format, to fill out electronically
- Download EPA Toxics Release Inventory List of Chemicals for Reporting - MS Excel format
- Download EPA Toxics Release Inventory List of Chemicals for Reporting - PDF format
- P2 Annual Fee Calculator Tool- Download MS Excel spreadsheet to help calculate annual pollution prevention fee
Toxic Use and Hazardous Waste Reduction Plans (due every three years by July 1):
Toxic Use and Hazardous Waste Reduction Plan Guidance and Worksheets:
- Download the entire PDF document:
- Download individual worksheets in Microsoft Word format to fill out electronically:
- Certification of Plan Completion
- Worksheet 1 - Facility Information
- Worksheet 2 - Management Policies
- Worksheet 3 - Ongoing Pollution Prevention Activities
- Worksheet 4 Toxic Substances - Worksheets 4A and 4B
- Worksheet 5 - Hazardous Waste Generation
- Worksheet 6 - Process Description
- Worksheet 7 - Identifying Opportunities
- Worksheet 8 - Technical Feasibility Analysis
- Worksheet 9 - Financial Analysis
- Worksheet 10 - Performance Goals
- EMS Alternative Application
Toxic Use and Hazardous Waste Reduction Resources on the Web:
- Zero Waste Network - search for TUHWR case studies by industry type, process type, or type of waste reduced
- Healthcare Environmental Resource Center - pollution prevention and compliance assistance information for the healthcare industry
- Toxics Use Reduction Institute (TURI) at UMASS Lowell
- OSHA Transitioning to Safer Chemicals Toolkit
- Subsport - chemical substitution support portal with ingredient and case study database
- Chemhat - chemical hazards and alternatives toolbox showing health effects, hazards, environmental impacts, and safer alternatives
- Washington State Department of Ecology - finding safer alternatives to toxic chemicals
- EPA's Safer Choice labeling program
- Green Seal Certified Products
- Electronic Product Environmental Assessment Tool
- Energy Star, Energy Efficient Products
- UMass Lowell Toxics Use Reduction Institute (TURI)
- EPA Sustainable Marketplace for greener products and services
If you have questions about TUHWR, please contact: