CAPACCIO’s EH&S Regulatory and Industrial News Blog

In an effort to “help industry and the environment prosper,” CAPACCIO has developed this blog to provide the latest news on environmental, health and safety related regulatory updates, management systems and sustainability topics.

To become an email subscriber to this blog and receive immediate notification when a new post has been made, look to the right and enter your email address in the “Email Subscription” box.  All the latest regulatory and industrial news will now be sent directly to your inbox.

For further information on our blog posts or if you need more information about our services, please contact Lucy Servidio  at 508.970.0033 extension 114 or lservidio@capaccio.com.

IMPORTANT: Source Registration e-mail from MassDEP Reply

You may have recently received an e-mail from the MassDEP with the subject line: IMPORTANT-Notice of EPA’s retirement of air pollution control devices effective for the 2013 submission. This does NOT mean that your control device needs to be replaced. The EPA recently changed their naming system which does not match all the options that are available on the MassDEP’s Source Registration forms. Therefore, the MassDEP is being forced to change the naming system in the Source Registration program. If your facility’s air pollution control device is not on the revised EPA list, the MassDEP will be sending you an e-mail listing your current control device and a list of similar names on the revised EPA list. The MassDEP is asking that you respond to their e-mail stating which revised name matches your air pollution control device. The MassDEP will then update your 2013 Source Registration to the revised name.

If you have any question or concerns, please contact Lynn Sheridan at 508.970.0033 ext. 122 or lsheridan@capaccio.com.

TURA Fee Increase Update Reply

As a follow-up to the TURA update in our last e-blast, CAPACCIO attended the TURA Administrative Council meeting on September 19, 2014. The Council voted 4 to 2 to move forward with increasing TURA Fees. In particular, they would like to see Option B be approved. The three options for increasing fees are at the link below:

http://www.capaccio.com/handouts/eblast/TURA_Fee_Adjustment_Proposal_8-19-14.pdf

Industry and public interest groups were both there to present comments. This will still have to go to public hearings in the fall and the Administrative Council said they would send notices of public hearings to all TUR filers and TUR planners. The Council also agreed to have public hearings in 4 regions of the state so that all stake holders can easily attend. If the fee increase of 50% is passed, it could add an additional $10,000 to big companies using a lot of chemicals. We’ll keep you posted.

For more information, please contact Lucy Servidio, CHMM, TURP, at 508.970.0033 ext. 114 or lservidio@capaccio.com.

CAPACCIO to present “Upcoming Changes to the ISO 14001 Standard” at SESHA NE/NY Mini-Conference Reply

On September 29 and 30, the New England and New York State Semiconductor Environmental Safety and Health Association (SESHA) chapters are jointly sponsoring a mini-conference in Albany, NY at SUNY College of Nanoscale Science and Engineering (CNSE)/SUNY Institute of Technology (SUNYIT). SESHA is the premier Environmental, Safety & Health association serving the high technology and associated industries and provides value to its members through ongoing education and professional development.

Among the presenters at the conference will be Daniel Forsythe, CHMM, TURP, RABQSA Auditor, Practice Area Leader for the Semiconductor and Electronics sectors at Capaccio Environmental Engineering, Inc. Mr. Forsythe’s presentation, “Upcoming Changes to the ISO 14001 Standard,” will walk attendees through the proposed changes detailed in the Draft International Standard (DIS), released for public enquiry in July 2014, and how they may impact your organization. One of the most noteworthy changes is the style of the standard itself, which is being written in accordance with Annex SL – a new high level structural framework that will be common across all management systems and will provide core text, common terminology, and core definitions. The proposed changes also reflect an overall shift toward tangibly improving environmental performance rather than simply improving the management system itself. The ultimate goal is for certified organizations to produce more fundamental ‘bottom line’ reductions in key environmental impact areas such as noise, gas, and water emissions.

For the complete agenda, directions, vendor information, sponsorship information, online registration and downloadable registration forms for this event, please visit: http://seshaonline.org/regions/ssabostonc/boston.php3

If you are unable to make it to SESHA, and want to learn more about the upcoming changes to the ISO 14001 standard, you may view CAPACCIO’s recent webinar recording on this topic.

http://www.capaccio.com/Resources/Event_Recs.html

We asked our webinar attendees the reason they wanted to attend our webinar, to which they responded:

Certified to ISO 14001:2004 & Want Info on ISO 14001:2015…..61
Have an Uncertified EMS & Exploring ISO 14001:2015 Certification…..23
Do Not Have an EMS and Have Limited Knowledge of ISO 14001…..18
Other Reason…..17

Based on the responses, the majority of our webinar attendees are already registered to ISO 14001 and were attending our webinar to gain more information on the forthcoming changes. Another great majority have an uncertified EMS and are exploring ISO certification for not only its value, but also from an EHS and financial standpoint.

CAPACCIO has worked with a number of our clients to develop and implement successful EHS systems and can provide guidance on how to prepare for these changes so your firm can be ready for certification. In regard to the upcoming ISO 14001 changes, conducting a gap analysis is the best first step in identifying what needs to happen for a company’s existing system to conform to the new changes.

For more information on ISO 14001/18001 or environmental, health and safety management systems or having a gap analysis performed for your company, please contact Dan Forsythe at 508.970.0033 ext. 135 or dforsythe@capaccio.com.

Important Toxics Use Reduction Act (TURA) Updates Reply

There are two recent policy developments in the TUR program.

First, at recent meetings of the Administrative Council, the Council voted to designate five chemicals/categories of chemicals as Higher Hazard Substances (HHS). The chemicals include: dimethylformamide (CAS 68-12-2), toluene diisocyanates (listed as: 2,4-TDI [584-84-9]; 2,6-TDI [91-08-7]; and TDI mixed isomers [26471-62-5]), hydrogen fluoride (CAS 7664-39-3), cyanide compounds (TURA #1016) and 1-bromopropane (n-propyl bromide (CAS 106-94-5). These designations are based on recommendations from the Science Advisory Board, TURI policy analyses, and discussions at TURA Advisory Committee and Council meetings. When a chemical/category is designated as a HHS, its reporting threshold is reduced from 10,000/25,000 pounds to 1,000 pounds for manufactured/processed or other-wise used in a calendar year.

Second, the Administrative Council is deliberating the need to address reduced revenues to the TURA program. These revenues have declined because the annual fee adjustments, required by the Act, have not been implemented since the inception of the program. At its next meeting, the Council will discuss three options for increasing fees (see link below):

http://www.capaccio.com/handouts/eblast/TURA_Fee_Adjustment_Proposal_8-19-14.pdf

All the options would provide revenues sufficient to meet the minimum mandatory statutory requirements. The TURA program is recommending option B, because it provides for mitigation of higher fees, particularly on smaller business. The Council is meeting on Friday, September 19th to discuss and vote on whether there will be a TURA fee increase. There will be a 21- day public comment period this fall.

The above information was supplied by Rich Bizzozero, Executive Director TUR Administrative Council, Executive Office of Energy and Environmental Affairs. If you would like to be notified of the 21-day public comment period, please contact rich.bizzozero@state.ma.us.

CAPACCIO’s Senior Vice President Lucy Servidio, CHMM, TURP, serves on the TURA Advisory Committee. If you have any questions, please contact her at 508-970-0033 ext. 114 or lservidio@capaccio.com.