The regulatory environment in massachusetts today and tomorrow
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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

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



We ll talk about
We’ll Talk About: Today…and…tomorrow

  • Trends and Themes (Tom)

  • Two in Detail: (Susan)

    • DEP Toxics

    • DFS Process Safety


Mental stretch big picture look
Mental stretch….& big picture look Today…and…tomorrow


1 what used to be beyond compliance is the new compliance
#1 Today…and…tomorrowWhat 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? Today…and…tomorrow


2 collaboration
#2 Collaboration - Today…and…tomorrow

  • 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 Today…and…tomorrowChemical 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 Today…and…tomorrow

  • 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 Today…and…tomorrow

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 Today…and…tomorrowProcess 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 Today…and…tomorrow

  • 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 Today…and…tomorrow

  • 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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