the regulatory environment in massachusetts today and tomorrow n.
Download
Skip this Video
Download Presentation
The Regulatory Environment in Massachusetts: Today…and…tomorrow

Loading in 2 Seconds...

play fullscreen
1 / 15

The Regulatory Environment in Massachusetts: Today…and…tomorrow - PowerPoint PPT Presentation


  • 113 Views
  • Uploaded on

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?.

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'The Regulatory Environment in Massachusetts: Today…and…tomorrow' - misha


Download Now An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
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:
  • Trends and Themes (Tom)
  • Two in Detail: (Susan)
    • DEP Toxics
    • DFS Process Safety
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
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 tbalf@nexusep.com

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 tbalf@nexusep.com

15