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Developing TUR 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.

Plans include:

  • Scope, including a management policy statement and employee notification 
  • Process characterization, a flow diagram of relevant production units and an inventory of toxics used in each relevant production unit
  • Unit of product for each described process
  • Determination of quantity, cost, purpose and fate of all toxic chemicals used

Plans must describe the options considered and the technical feasibility and economic impacts of implementing those options. Process changes undertaken must be described with a schedule for implementation. 

TUR techniques:
  • 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 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