If your facility is required to do a Toxics Use Reduction (TUR) Plan under 310 CMR 50.00, you will need to send out notification to your employees that this is a TUR planning year and solicit ideas for reducing the use and byproduct of the reportable chemicals your facility triggers for.  This notification must be made by January 1, 2012!

There are three options for TUR Plan format: A conventional TUR Plan, a Resource Conservation Plan, or an Environmental Management System (EMS).

The notification for a conventional TUR Plan must:

• Include requirements of the plan
• Identify the toxics and production units for which a plan will be submitted
• Provide the criteria for plan
• Solicit comments or suggestions from all employees on toxics use reduction options

The notification for a Resource Conservation Plan must:

• Include requirements of the plan
• Identify the natural asset being considered as the focus of the plan
• Solicit comments or suggestions from all employees on resource conservation options for that asset

There is no notification requirement for EMSs, but there are requirements for:

• A written environmental policy that expresses how the facility manages and makes a commitment to:

(a) Compliance with environmental legal requirements

(b) Pollution prevention through source reduction and toxics use reduction

(c) Continual improvement of the EMS and environmental performance

• Procedures for communicating environmental and EMS information throughout the facility, including EMS awareness programs for all employees

Remember, you will need to complete and have evidence – a memo, an email, a posting – of the notification sent to employees by the January 1 deadline.

For more information, please contact Linda Swift at 508-970-0033 ext. 119 or lswift@capaccio.com.