How will MassDEP “judge” the quality of a TURA EMS?
If MassDEP inspects a facility with a TURA EMS, it may check to see if the EMS is in place and has all the elements required in 310 CMR 50.80. MassDEP’s inspection would focus primarily on whether the required elements are in place and documented. For example, a TURA EMS must have environmental and compliance training. As part of an inspection, MassDEP may determine whether such training is documented in the EMS. However, in general MassDEP would not evaluate the quality of the training.