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RTK in NYC. Community Right-to-Know In New York City. Who I am: George McCauley Industrial Hygienist/Inspector New York City Department of Environmental Protection (DEP). Joined today by my colleague and friend: Denise Clarke Industrial Hygienist NYC Department of

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rtk in nyc

RTK in NYC

Community Right-to-Know

In

New York City

slide2
Who I am:

George McCauley

Industrial Hygienist/Inspector

New York City Department

of

Environmental Protection

(DEP)

slide3
Joined today by my colleague and friend:

Denise Clarke

Industrial Hygienist

NYC Department

of

Environmental Protection

(DEP)

slide4
Where we work in DEP:

Emergency Response and Technical Assessment

Bureau of Police and Security

(The Hazmat Group)

slide5
Our headquarters in Queens:

96-05 Horace Harding Expressway

Corona, NY 11373

(Lefrak City – The ‘Low Rise’ Building)

slide6
The hazmat group is nearly all comprised of chemists and chemical engineers.

We take our responsibility to protect the public very seriously.

slide7
The group is responsible for:

Community Right-to-Know

Emergency Response

Airborne Bio-Organism Surveillance

Event Deployment

slide8
Clients in the DEP RTK Database:

Approximately 17,000

We try to get to everyone once a year.

slide9
Origins of RTK Legislation:

The Bhopal Disaster

December 3, 1984

Bhopal, India

(Central Indian state of Madhya Pradesh)

Union Carbide

Forty Metric Tons in About an Hour

slide10
Methyl Isocyanate

Synthetic intermediate in carbaryl process

At least 8,000 dead

Probably half a million affected

Litigation ongoing to this day

People / Plants / Animals

slide11
Eight months later:

Union Carbide, Kanahwa Valley, WV

August 11, 1985

A second release:

Approximately two metric tons

slide12
SARA

Superfund Amendments and Reauthorization Act

Signed by President Ronald Reagan

October 17, 1986

A few weeks later:

EPCRA

slide13
Emergency Planning and Community

Right-to-Know Act

November 1986

Laws and Regulations adapted

by New York City

within about two years.

slide14
Who needs to file?

The owner or operator of a facility must report all hazardous substances in a quantity equal to or greater than a threshold reporting quantity (TRQ)

Where to get started?

www.nyc.gov/dep/tier2filing

slide15
Additionally, Risk Management Plans (RMPs) must be filed for extremely hazardous substances or regulated toxic substances present at or above federally determined levels.

(TPQs – Threshold Planning Quantities)

slide16
It is the responsibility of each facility to consults NYC’s RTK laws and regulations to determine compliance.

Facility exemptions are granted upon written notification to DEP, confirmed by inspection.

slide17
What is a hazardous material?

Any substance for which a facility must maintain an SDS under the OSHA Hazard Communication Standard.

slide18
How does DEP find facilities?

Self-reporting

Surveys

Complaints

slide20
Types of facilities in our database?

Dry Cleaners

Automotive Shops

Universities

Office Towers

Utilities

Electroplaters

Explosives Manufacturers

slide21
Are DEP facilities subject to RTK reporting requirements?

Answer: Yes

(as are all other city agencies)

slide22
The Inspection Process:

What to expect?

Professionalism

Courtesy

Respect

Chemical Competence

slide23
There is no need for anxiety.

We are not inspecting to ruin your day.

Our relationship is ideally symbiotic.

The regulators and the regulated share common objectives.

slide24
Inspections are generally unannounced.

Inspectors carry DEP photo IDs and department-issued shields (badges).

slide25
If we arrive at an inopportune time:

staff unavailable or otherwise urgently occupied,

it is acceptable to request that we reschedule.

However, if you are open for business, and staff is available, it is best to let the inspection proceed.

slide26
Inspectors will ask to speak with the person identified on the facility inventory form, or his or her delegate, or the building engineer or EH&S officer, and will request an escort of the facility.
slide27
Things that should be available:

Tier II paperwork

SDSs

Posted permits for inspection

slide28
The inspector will take an inventory, while simultaneously observing general housekeeping.

Labeling is a focus. Everything should be labeled. Labeling should be readable, firmly affixed, and representative of contents.

slide29
Things we look for:

Cross-reactive chemicals adequately sequestered?

Flammables in flammables cabinets or storerooms?

Gas cylinders chained?

Referrals to NYFD or OSHA are possible.

slide30
Back at the office in Lefrak, inspections are entered into our inspection database.

Does DEP send a copy of the inspection report to clients?

No, but ‘in-compliance’ emails are not uncommon.

slide31
Notice of Violation (NOV) subsequent to inspection.

Primarily for failure to file, much less common for access denied.

slide32
Violations are mailed by USPS First Class mail unless we are unable to locate corporate information in NYS DOS (New York State Department of State) registration database.

In such cases NOVs are served in person by a Peace Officer.

slide33
It is important to respond to

a Notice of Violation

1st NOV: $500 increases to $5,000.

2nd NOV: $3,500 increases to $10,000.

3rd NOV:10,000 increases $20,000.

slide34
Violations may be contested in person or via counsel:

ECB (the Environmental Control Board)

144-06 94th Avenue, Jamaica, Queens.

Hearing date is indicated on the NOV (generally, 8-10 weeks from date of inspection).

slide35
Most clients do not contest, and simply mail in the fine prior to the ECB hearing date.

Repeat violations can get very expensive, and are unnecessary.

slide37
Reducing annual filing fees while crafting a safer workplace:

Properly dispose of chemicals no longer being used.

Review the facility inventory form (FIF) and delist chemicals no longer actually on-site.

Remove duplicate entries form the FIF.

File yourself if at all possible.

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