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Developing Plans

A TUR plan must establish two and five-year goals for by-product reduction of each listed chemical used in that facility. Plan documents are maintained at the facility and a plan summary is submitted to the State. Plans may be inspected by an official from the Massachusetts Department of Environmental Protection on request. 

Plans are formally updated every two years, including an assessment of the implementation schedule and TUR commitments.

Plans include:

  • A management policy statement
  • Scope of the plan
  • Employee notification
  • A process characterization, including a flow diagram of relevant production units
  • Unit of product identified for each described process
  • Quantity, cost, purpose and fate of all toxic chemicals used

Additionally, plans must describe the options considered, and a description of the technical feasibility and economic impacts of implementing them should be included in the plan. Process changes undertaken must be described with a schedule for implementation. Certain TUR techniques are recognized in the law for identifying or creating options.

TUR techniques recognized in the law include:
  • Toxic chemical substitution
  • Production process modification 
  • Finished product reformulation
  • Production modernization
  • Improvements in operations and maintenance
  • In-process recycling of production material

The plan summary submitted to the State must include data -- normalized by production volume -- about historic and projected change in facility-wide use and individual process byproduct generation for each chemical.

The Chief Executive Officer or any senior management official of the firm must sign the plan certification statement affirming the accuracy of the statements in the plan and the information used. The plan certification statement must also be signed by a TUR Planner certified by the State