The regulatory environment in massachusetts today and tomorrow
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The Regulatory Environment in Massachusetts: Today…and…tomorrow PowerPoint PPT Presentation


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The Regulatory Environment in Massachusetts: Today…and…tomorrow. Thomas Balf, Nexus Environmental Partners, Policy Advisor to MBC & Susan Smits, Mabbett & Associates, Inc. Co-Chair , Safety, Environmental and Facilities Committee . What are the Environmental, Health and Safety Issues?.

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The Regulatory Environment in Massachusetts: Today…and…tomorrow

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The regulatory environment in massachusetts today and tomorrow

The Regulatory Environment in Massachusetts: Today…and…tomorrow

Thomas Balf, Nexus Environmental Partners,

Policy Advisor to MBC

&

Susan Smits, Mabbett & Associates, Inc.

Co-Chair , Safety, Environmental and Facilities Committee


What are the environmental health and safety issues

What are the Environmental, Health and Safety Issues?


We ll talk about

We’ll Talk About:

  • Trends and Themes (Tom)

  • Two in Detail: (Susan)

    • DEP Toxics

    • DFS Process Safety


Mental stretch big picture look

Mental stretch….& big picture look


1 what used to be beyond compliance is the new compliance

#1 What used to be “Beyond Compliance” is the New Compliance

  • Carbon management

  • Green Building requirements

  • Pollution Prevention/Chemicals


Where were these issues 5 years ago

Where were these issues 5 years ago?


2 collaboration

#2 Collaboration -

  • Recent Positive Experience:

    • DEP

    • DPHs

    • Cambridge Public Health

    • Role of trade assocs

  • Concerns…

    • Follow through in time of limited resources

    • Innocuous language that becomes lever for more…

    • Language written for enforcement and inspectors


3 chemical policy not this year but

#3 Chemical Policy – not this year, but…

  • California – moving ahead aggressively

  • Green Screen: assessment tools being developed

  • NGOs: EPA, Cleangredients, Clean Production Action


Massdep industrial wastewater toxics discharge reporting

MassDEP Industrial Wastewater Toxics Discharge Reporting

  • Purpose: identify/address significant environmental problems from the discharge of toxics to sewers e.g perchlorate case

  • Mandatory toxics discharge reporting for 3,400 MA facilities including LQGs and random facilities

  • 1900+ chemicals require reporting if discharged

  • Facilities will receive a notification letter

  • Web based reporting via eDEP

  • Excel chemical inventory files can be partially uploaded/imported.


Massdep industrial wastewater toxics discharge reporting1

MassDEP Industrial Wastewater Toxics Discharge Reporting

Potential Impacts to MBC Members

  • Potentially significant reporting burden

  • Possible need to perform chemical inventory and MSDS review

  • Data may be publicly available

  • Need for senior management official certification

  • Need to register/use eDEP system


State fire marshall s office process safety regulation

State Fire Marshall’s Office Process Safety Regulation

Purpose: Minimize risk to public from harmful exposure due the unsafe processing of hazardous chemicals.

Danvers Explosion


Draft 527 cmr 33 hazardous material processing

Draft 527 CMR 33 Hazardous Material Processing

  • Developing Process Safety Reg. and permit program

  • Categories based on amount processed e.g. vessel size

    • 1 = <1.5 gallons

    • 2 = 1.5 – 15 gallons

    • 3 = 15 – 60 gallons

    • 4 = > 60 gallons

    • 5 = RMP or OSHA Process Safety

  • Increasing regulatory burden for each category

    • Annual permit from Fire Department for Cat. 2 – 5

    • All require emergency planning and post incident analysis

    • Category 4 = limited process safety hazard eval

MBC

Tom Balf [email protected]

14


Draft 527 cmr 33 hazardous material processing1

Draft 527 CMR 33 Hazardous Material Processing

  • Exemptions include:

    • NFPA Hazards if all < 2

    • pH adjustment systems and water purification

    • Boilers, emergency generators, etc.

    • Collection of hazardous waste, SAAs, etc.

  • Impacts to MBC Member Companies

    • Increased regulatory burden

    • Permit fees

    • Fire Department inspections

    • Possible need for consultant

MBC

Tom Balf [email protected]

15


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