In January 2007, the US Department of Transportation (DOT) put in place a number of revisions to better align the DOT requirements with international requirements for shipping hazardous materials. Some of these requirements were effective as of January 1, 2007 and others had delayed compliance deadlines.
The requirements regarding the sequence of the information in a proper shipping description on a shipping paper used to ship hazardous materials regulated by the DOT had a delayed compliance deadline of January 1, 2013.
As of January 1, 2013, the proper sequence of information in a shipping description on a shipping paper is as follows:
-the proper shipping name (from the Hazardous Materials Table)
-the hazard class
-the packing group
For more information, refer to the federal register at http://www.gpo.gov/fdsys/pkg/FR-2006-12-29/html/06-9849.htm, the DOT regulations 49 CFR 172.202, or contact Linda Swift at (508)970-0033 extension 119 or via email at firstname.lastname@example.org.
CAPACCIO has played a part in helping to clarify questions about the 527 CMR 33 Hazardous Materials Process or Processing Regulation by submitting questions to the Board of Fire Prevention. Answers to our questions, as well as answers to questions from others, are available on the Massachusetts Department of Fire Services website at this link: http://www.mass.gov/eopss/docs/dfs/osfm/cmr/527-cmr-33-faq.pdf
For more information or if you need help complying with this regulation, please contact Linda Swift at 508-970-0033 ext. 119 or email@example.com or Chris Walton at 508-970-0033 ext. 139 or firstname.lastname@example.org.
Did you know that you may be required to notify more than one section of the Massachusetts Department of Environmental Protection (MassDEP) when you have a spill that requires implementation of your hazardous waste contingency plan?
Spills or releases of hazardous waste – whether inside the facility or outside to the environment – are reportable to the MassDEP Bureau of Waste Prevention at the appropriate MassDEP Regional Office when there is an imminent or actual emergency involving hazardous waste that requires the facility to activate its hazardous waste contingency plan. This requirement is in addition to notification (if required) to the MassDEP Emergency Response Section per the Massachusetts Contingency Plan (310 CMR 30.400).
The MassDEP hazardous waste regulations require that Large Quantity Generators (LQGs) have a written hazardous waste contingency plan (310 CMR 30.341(1)(b)) that outlines what to do in the event of an emergency involving hazardous waste. Even if a facility has to activate the hazardous waste contingency plan for something as simple as calling the Emergency Coordinator for a spill of hazardous waste inside the facility, the facility must notify the MassDEP Bureau of Waste Prevention. The same applies if you have a bulging or leaking drum of hazardous waste that is overpacked by your emergency response team and then shipped off-site for proper disposal.
These reporting requirements are outlined in 310 CMR 30.341(b) and 310 CMR 30.521(e)(7) and apply to LQGs when there is an imminent or actual emergency involving hazardous waste which triggers the need to implement the hazardous waste contingency plan. This applies even if it does not result in a reportable release pursuant to 310 CMR 40.000 (The Massachusetts Contingency Plan requirements).
We recommend developing a methodology of who to report to and when, and including it in your hazardous waste contingency plan so that it is readily available to personnel responsible for reporting.
What to report, when, and to whom, can be confusing. Please contact Linda Swift at 508.970.0033 extension 119 or email@example.com with any questions you may have regarding reporting spills.
Linda Swift, CAPACCIO’s Manager of the EH&S Compliance and Systems Group, will present New Hazardous Materials Processing Regulations and Preventive Emergency Planning at the upcoming Central Massachusetts Business Environmental Network (CMBEN) meeting on September 11 from 9-11 a.m. The meeting is in partnership with the Worcester Regional Chamber of Commerce and will be held at WRCC, 446 Main Street, Suite 200. There is no cost for this meeting, however space is limited, so please register soon. To register, e-mail Mary Hubbard of the Worcester Regional Chamber of Commerce at firstname.lastname@example.org, or call her at (508) 753-2924.
Ms. Swift’s presentation will delve into the wide scope of the new Massachusetts Department of Fire Services (DFS) Hazardous Material Processing regulation (527 CMR 33), which involves compliance to requirements of a number of agencies. Ms. Swift will talk about the applicability of and compliance to 527 CMR 33, and include the scope of the regulation, exemptions, determining applicability to the regulation, how to achieve compliance with the regulation, and other requirements that may be applicable.
Rick Reibstein of the Massachusetts Office of Technical Assistance will discuss the requirements in the context of emergency planning generally and how an efficient response will include an examination of options for accident and pollution prevention, as well as combining related compliance and performance efforts.
For more information on the new regulation and how it may pertain to your facility, please contact Linda Swift at 508-970-0033 x119 or email@example.com.