In Section B4 of the Progress Report, does “all” refer to reportable spills only or any size spill, even drips?
The intent of Question 4 in Section B is to verify that a company is seeking to ensure that all leaks, spills, releases and byproduct generation are minimized to the extent practicable. This would include spills reportable under various government programs as well as those that are not, since any uncorrected spilling or leaking would run counter to toxics use reduction. 31. In Section B5 of the Progress Report, does “all regulatory requirements” mean any applicable regulatory requirements (e.g. OSHA, RoHS, etc.) or only all environmental regulatory requirements that are applicable to a company’s operations? Question 5 refers only to US federal and Massachusetts environmental regulatory requirements since a TURA EMS requires companies to have a process to identify their environmental legal requirements (310 CMR 50.82(3)). However, in the spirit of TUR planning, a company should consider all of the requirements and costs that the use of toxics pose for a company (e.g., health and safety,
Related Questions
- What should be included in the progress report section of a Competing Renewal (Type 2) IMSD Application, and how is the progress on outcomes evaluated?
- In Section B6 of the Progress Report, does a TURA EMS need to have been audited at least once between 2006 and 2008?
- In Section B4 of the Progress Report, does "all" refer to reportable spills only or any size spill, even drips?
