It’s hard to say no to a Super Hero… Reply

 

I’ve been asked to present industry’s perspective on practical solutions to reducing toxics in the work place at a forum sponsored by the Cancer Council of Australia in Melbourne, Australia on May 3 2012. I’m following a presentation given in 2009 by Pam Eliason of the Toxics Use Reduction Institute (TURI) where she was introduced as having the answers to all of industry’s toxics use problems. I thought only a super hero could meet those expectations so I got myself a cape and now I am Super TURP ( Toxics Use Reduction Planner).

My super power is opening people’s minds to new ways of doing things. This results in using less toxic chemicals and generating less byproduct per widget manufactured. This mind bending ability can make companies more profitable and protect their greatest assets, their employees!

In order to prepare for my Australia presentation I attended a conference that  TURI held on April 12, 2012. I was interested in learning more about safer alternatives and attended the Green Chemistry track. I must confess, I had an ulterior motive to attending the conference. I wanted to get interviews with TUR Planners about their successes with TUR planning so that I could share them with the folks in Australia.

I decided to wear my Super TURP cape to the conference in order to get street cred, or maybe sympathy, from the crowd. It worked! I was able to get 10 companies to give me their input on what they think is the biggest benefit is to using the TUR planning process in their companies.

Please listen to the comments from Cindy Keegan, Manager, Environmental, Health& Safety Analogic Corporation and David Kiddo, Global Business Manager, Wire & Cable, Alpha Gary by clicking on each of the play buttons below.

Comments from Cindy Keegan


Comments from David Kiddo


Isn’t it great that Australia is looking to Massachusetts as a model for reducing cancer in the workplace? I’m proud to be representing TUR Planners and spreading the good word about the Toxics Use Reduction Act (TURA).

Need some assistance in making your company’s TUR Plan leap over tall buildings in a single bound…reduce payback periods…open up TUR Team minds to new ideas…we have a team of super heroes at CAPACCIO…just waiting to wear our cool capes!

Look for future blogs from down under …there will be photos with emus…maybe…Lucy

(Right) CAPACCIO’S Lucy Servidio with the Photofabrication Engineering TUR Team

CAPACCIO’s Travis Wheeler…Boy Wonder (Helping companies reduce the use of toxic chemicals)

TUR Planning – Notification due January 1st! Reply

If your facility is required to do a Toxics Use Reduction (TUR) Plan under 310 CMR 50.00, you will need to send out notification to your employees that this is a TUR planning year and solicit ideas for reducing the use and byproduct of the reportable chemicals your facility triggers for.  This notification must be made by January 1, 2012!

There are three options for TUR Plan format: A conventional TUR Plan, a Resource Conservation Plan, or an Environmental Management System (EMS).

The notification for a conventional TUR Plan must:

  • Include requirements of the plan
  • Identify the toxics and production units for which a plan will be submitted
  • Provide the criteria for plan
  • Solicit comments or suggestions from all employees on toxics use reduction options

The notification for a Resource Conservation Plan must:

  • Include requirements of the plan
  • Identify the natural asset being considered as the focus of the plan
  • Solicit comments or suggestions from all employees on resource conservation options for that asset

There is no notification requirement for EMSs, but there are requirements for:

  • A written environmental policy that expresses how the facility manages and makes a commitment to:

(a) Compliance with environmental legal requirements

(b) Pollution prevention through source reduction and toxics use reduction

(c) Continual improvement of the EMS and environmental performance

  • Procedures for communicating environmental and EMS information throughout the facility, including EMS awareness programs for all employees

Remember, you will need to complete and have evidence – a memo, an email, a posting – of the notification sent to employees by the January 1 deadline.

For more information, please contact Linda Swift at 508-970-0033 ext. 119 or lswift@capaccio.com.

EPCRA 313 and TURA Reporting/Planning Reply

It is never too early to start thinking about collecting your chemical use and emissions data for calendar year 2011. Nor is it too early to begin evaluating your reporting thresholds for Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 Toxic Chemical Release Inventory (Form R) and Massachusetts Toxics Use Reduction Act (TURA) Toxics Use (TUR Form S) Reporting.  Reports are due July 1, 2012.  

Hydrogen sulfide is added to TRI requirements for 2012

In the October 17 edition of the Federal Register, the US Environmental Protection Agency (EPA) announced that they dropped their stay on hydrogen sulfide gas because they had enough scientific evidence to change its status to reportable. Companies will have to report if they manufacture, process, or use hydrogen sulfide in excess of reporting thresholds. This decision will likely impact utilities, petroleum refineries, and metal and coal mining companies. The change will take effect in the 2012 Form R reporting cycle with reports due July 1, 2013.

Please note: In a recent conversation with Dwight Peavey, TRI Coordinator for EPA New England, Dwight stressed that having back-up for threshold determinations and emission calculations will be very important in the upcoming reporting year. EPA is using other databases (e.g., Tier 2 and Risk Management Programs) to connect the dots and find companies that should be reporting.

 Newly Added TURA Chemicals

The TURA Administrative Council voted this year to separate hexavalent chromium compounds  from the general chromium compounds category, and make hexavalent chromium compounds a Higher Hazard Substance (HHS).   They also voted to designate formaldehyde as a HHS.  There is a formal public comment period on these proposed regulation changes that began November 11 and ends December 1, 2011.  Go to:  http://www.mass.gov/eea/waste-mgnt-recycling/toxics/toxic-use-reduction/hearing-amendments-to-the-toxic-substances-list.html  to find information on where you can obtain a copy of the proposed regulation changes and to submit comments, if you wish to do so. 

If the proposed regulations are finalized before the end of calendar year 2011, then 2012 would be the first year that hexavalent chromium compounds and formaldehyde would have a 1000 pound (lb) reporting threshold.  Other chromium compounds (most often trivalent) would still have a 25,000 lb threshold for manufactured and processed, or 10,000 lb for otherwise used.  The 2012 reports would need to be filed with the MassDEP by July 1, 2013. 

TUR Planning

2012 is a TUR planning year. Don’t forget to post your Employee Notification that reminds employees at your company that you will be going through the TUR planning process and solicit their input on ways to reduce toxics use and byproduct. 

Plan Summaries/Progress Reports and Plan Certification need to be completed and submitted by July 1, 2012.  You will need to have a traditional TUR Plan, a TUR Environmental Management System, or a Resource Conservation Plan in place by July 1st.   Reminder: plans must be certified by a MassDEP Certified Toxics Use Reduction Planner.

 If you need any help with developing a methodology that will past EPA and MassDEP muster, contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com or Lucy Servidio at 508.970.0033 ext. 114 or lservidio@capaccio.com.

EPA Proposes Changes to EPCRA Section 312 Tier I and Tier II Forms Reply

On August 8, 2011, the Environmental Protection Agency (EPA) published a proposed rule that suggests changes to the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 (Tier I and Tier II) reports (40 CFR 370).  The proposed regulations include additions and revisions to the Tier I and Tier II forms so the forms can be more useful to state and local agencies and better inform the public on the chemical hazards in their communities. Although the proposed regulations refer to Tier I and Tier II forms, most state and local authorities only require a Tier II form from facilities that trip reporting thresholds.

EPA proposes to add the following to Tier I and Tier II forms:

  • Add entries for the facility’s identification number under EPCRA 313 (Toxic Chemical Release Inventory – Form R reporting) and Clean Air Act Risk Management Programs, if applicable.
  • Add an entry for the number of occupants at the facility.
  • Add entries for the facility’s parent company name, address, and phone as well as the company’s Dun and Bradstreet number.
  • Add entries for name and contact information of the facility representative required under EPCRA Section 303.
  • Add entries for name, title, and phone number of the person knowledgeable or responsible for completing the information on the Tier II form.
  • Add an entry to indicate whether the facility is also subject to Extremely Hazardous Substance (EHS) notification requirements under EPCRA Section 302.

EPA is also proposing to revise the following existing entries currently on the Tier II form:

  • Revise the current range codes for maximum and daily average amounts of hazardous chemicals to narrower codes than the existing codes to be more useful to Local Emergency Planning Committees (LEPCs) for effective emergency response planning.
  • Revise the reporting of chemicals (i.e., pure chemicals versus mixtures) to make it more user friendly for state and local authorities by providing separate entries for pure chemicals and mixtures.
  • Revise the form to allow for description of the types of storage and storage conditions rather than using codes.

EPA is soliciting comments on the proposed rule until October 7, 2011.

Please contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com with any questions you may have regarding these proposed changes to EPCRA 312 reporting.