The letter was sent by Suzi Peck, Director of the Toxics Use Reduction Program, Bureau of Waste Prevention, for the MassDEP
Facility Manager and/or Toxics Use Reduction Planners: 2012 is a planning year under the Toxics Use Reduction Act (TURA) and facilities covered by TURA are required to complete their TURA planning for this planning cycle by July 1, 2012. Last December, MassDEP sent a postcard alerting that notice to employees regarding the planning process was to be completed by January 1, 2011. Facilities that are required to submit a Form S for at least one chemical by July 1, 2012, and who have submitted a Form S for that chemical on a prior year, are required to complete one of three types of planning for the 2012 planning year:
Toxics Use Reduction (TUR) Planning Resource Conservation (RC) Planning Environmental Management Systems (EMS)
Toxics Use Reduction (TUR) Planning If a facility has completed only one TUR plan and one TUR plan update, then the facility is required to develop a toxics use reduction plan or plan update, and to submit a TUR Plan Summary to MassDEP by July 1, 2012. In addition, if a facility prepared a Resource Conservation Plan in 2010, it must return to TUR planning for the 2012 planning cycle or integrate TUR planning into an Environmental Management System. Facilities that completed aResource Conservation Plan in 2010 are also required to submit a Resource Conservation Progress Report to MassDEP by July 1, 2012.
Resource Conservation Planning If a facility has completed a TUR plan and two plan updates (i.e., completed TUR plans for three planning cycles), it may elect to prepare a Resource Conservation Plan for the 2012 planning year. Resource conservation planning is aimed at reducing energy, water, materials, or non-reportable chemicals. This option may be attractive to facilities that have succeeded in reducing toxics use and are looking for other opportunities to further environmental improvement and facility efficiency. If you choose this option, submit a Resource Conservation Plan Summary (instead of a TUR Plan Summary) to MassDEP by July 1, 2012, documenting your planning effort. In addition,if your facility did a Resource Conservation plan in planning year 2008, and completed a TUR plan and a Resource Conservation Progress Report in 2010, then you may return to Resource Conservation planning in 2012.
Environmental Management Systems If a facility has completed a TUR plan and two plan updates (i.e., completed six years of TUR planning), it may integrate TUR into its Environmental Management System (EMS). This option allows companies that already have an EMS to integrate TUR into this more comprehensive system, thereby reducing duplication of effort. If you choose this option, then submit an EMS Progress Report to MassDEP by July 1, 2012 documenting that your EMS addresses toxics use reduction.
Plan Submittals due by July 1, 2012 Depending on which option you choose, a TUR Plan Summary, RC Plan Summary, or EMS Progress Report must be submitted to MassDEP by July 1, 2012. This means that all required planning must be completed before this date. MassDEP encourages facilities to file Plan Summaries online through eDEP, available at: www.mass.gov/dep/service/compliance/edeponlf.htm
Plan Certifications TUR Plans must be certified by a MassDEP approved Toxics Use Reduction Planner. RC Plans must be certified by a TUR Planner that also has specific training in resource conservation (see 310 CMR 50.63) and has been approved by MassDEP to certify RC Plans. EMS Progress Reports must be certified by either a TUR Planner with training in EMS and approved by MassDEP to certify EMS plans, or by an EMS professional with training in TUR.
For more guidance on certification requirements, please consult the MassDEP web site at: http://www.mass.gov/dep/toxics/approvals/turforms.htm#cert
If you do not have a certified in-house TUR Planner, you should consider hiring a general practice TUR Planner to guide you through the planning process. An updated list of certified Planners (as of February 2012) is available on MassDEP’s web site at:www.mass.gov/dep/toxics/tura/planners.htm
Guidance, Training, and Technical Assistance Helpful web links for further guidance, training, and technical assistance resources include:
Regulations, Fact Sheets and Guidance: MassDEP www.mass.gov/dep/toxics/laws/policies.htm
Continuing education training sessions on TUR planning, RC planning and EMS: MassDEP http://www.mass.gov/dep/toxics/tura/training.htm
This site includes links to training and workshops provided by the Toxics Use Reduction Institute, Office of Technical Assistance and Technology and MassDEP.
For questions or more information on TURA planning requirements please contact the MassDEP staff listed below:
Toxics Use Reduction Planning, Lynn Cain, email@example.com, 617-292-5711 Resource Conservation Planning, Lynn Cain, firstname.lastname@example.org, 617-292-5711 Environmental Management Systems, Cynthia Chaves, email@example.com, 617-292-5848