Developing TUR Plans
Toxics Use Reduction (TUR) plans are developed according to the regulations and must be updated every two years. 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.
- The scope of the plan
- The process, including a diagram that shows relevant processes and flow of toxic chemicals through these processes
- The unit of product, which is used to normalize data for changes in production
- The purpose, quantity, cost and fate of all toxic chemicals used
- The options considered and the technical feasibility and economic impacts of implementing those options.
The plan summary submitted to the State must include data - normalized by production volume - about historic and projected changes in facility-wide use and individual process byproduct generation for each chemical.
A 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.
Toxics Use Reduction (TUR) techniques that must be considered in TUR Plans include:
- Toxic chemical substitution
- Production process modification
- Finished product reformulation
- Production modernization
- Improvements in operations and maintenance
- In-process recycling of production material