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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


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

Environmental Protection

(DEP)


Where we work in DEP:

Emergency Response and Technical Assessment

Bureau of Police and Security

(The Hazmat Group)


Our headquarters in Queens:

96-05 Horace Harding Expressway

Corona, NY 11373

(Lefrak City – The ‘Low Rise’ Building)


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

We take our responsibility to protect the public very seriously.


The group is responsible for: chemical engineers.

Community Right-to-Know

Emergency Response

Airborne Bio-Organism Surveillance

Event Deployment


Clients in the DEP RTK Database: chemical engineers.

Approximately 17,000

We try to get to everyone once a year.


Origins of RTK Legislation: chemical engineers.

The Bhopal Disaster

December 3, 1984

Bhopal, India

(Central Indian state of Madhya Pradesh)

Union Carbide

Forty Metric Tons in About an Hour


Methyl Isocyanate chemical engineers.

Synthetic intermediate in carbaryl process

At least 8,000 dead

Probably half a million affected

Litigation ongoing to this day

People / Plants / Animals


Eight months later: chemical engineers.

Union Carbide, Kanahwa Valley, WV

August 11, 1985

A second release:

Approximately two metric tons


SARA chemical engineers.

Superfund Amendments and Reauthorization Act

Signed by President Ronald Reagan

October 17, 1986

A few weeks later:

EPCRA


Emergency Planning and Community chemical engineers.

Right-to-Know Act

November 1986

Laws and Regulations adapted

by New York City

within about two years.


Who needs to file? chemical engineers.

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


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)


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.


What is a hazardous material? NYC’s RTK laws and regulations to determine compliance.

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


How does DEP find facilities? NYC’s RTK laws and regulations to determine compliance.

Self-reporting

Surveys

Complaints


If a regulated facility, when do you need to file? NYC’s RTK laws and regulations to determine compliance.

In NYC by March 1st of each year.


Types of facilities in our database? NYC’s RTK laws and regulations to determine compliance.

Dry Cleaners

Automotive Shops

Universities

Office Towers

Utilities

Electroplaters

Explosives Manufacturers


Are DEP facilities subject to RTK reporting requirements? NYC’s RTK laws and regulations to determine compliance.

Answer: Yes

(as are all other city agencies)


The Inspection Process: NYC’s RTK laws and regulations to determine compliance.

What to expect?

Professionalism

Courtesy

Respect

Chemical Competence


There is no need for anxiety. NYC’s RTK laws and regulations to determine compliance.

We are not inspecting to ruin your day.

Our relationship is ideally symbiotic.

The regulators and the regulated share common objectives.


Inspections are generally unannounced. NYC’s RTK laws and regulations to determine compliance.

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


If we arrive at an inopportune time: NYC’s RTK laws and regulations to determine compliance.

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.


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.


Things that should be available: 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.

Tier II paperwork

SDSs

Posted permits for inspection


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.


Things we look for: observing general housekeeping.

Cross-reactive chemicals adequately sequestered?

Flammables in flammables cabinets or storerooms?

Gas cylinders chained?

Referrals to NYFD or OSHA are possible.


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.


Notice of Violation (NOV) subsequent to inspection. our inspection database.

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


Violations are mailed by USPS First Class mail our inspection database.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.


It is important to respond to our inspection database.

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.


Violations may be contested in person or via counsel: our inspection database.

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).


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.


Enforcement Discretion prior to the ECB hearing date.


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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