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.

MetroWest Medical Center Hospitals Receive “Greenhealth Partner For Change” Award Reply

The Practice Greenhealth Environmental Excellence Awards were presented June 5 in Cleveland, Ohio, at the CleanMed Conference & Exhibition, the premier national environmental conference for leaders in health care sustainability. Among the winners were MetroWest Medical Center’s two hospitals, Leonard Morse Hospital located in Natick, MA and Framingham Union Hospital, located in Framingham, MA, who were formally acknowledged for their environmentally preferable practices with Practice Greenhealth’s 2014 “Greenhealth Partner for Change” award. The award is one of the environmental excellence awards given by the organization each year to honor outstanding environmental achievements in the health care sector.

Practice Greenhealth is the nation’s leading health care community that empowers its members to increase their efficiencies and environmental stewardship while improving patient safety and care through tools, best practices and knowledge. The “Greenhealth Partner for Change” award recognizes health care facilities that continuously improve and expand upon their mercury elimination, waste reduction, recycling and source reduction programs. At a minimum, facilities applying for this award must be recycling 15 percent of their total waste, must have reduced regulated medical waste, be well along the way to mercury elimination, and have developed other successful pollution prevention programs in many different areas.

In 2013, CAPACCIO joined the MetroWest Medical Center’s Green Team. On a monthly basis, CAPACCIO compiles and analyzes sustainability data from facility representatives and vendors and reports to staff on progress toward their goals. CAPACCIO was also responsible for gathering and summarizing numerous metrics and programmatic elements to complete the Practice Greenhealth Award Application. CAPACCIO continues to take the hospital to even greater heights by providing thought leadership and assistance with MetroWest Medical Center’s sustainability programs.

CAPACCIO is a women-owned environmental, health and safety consulting and engineering firm with a solid track record of assisting industrial and institutional clients toward sustainable growth. Our commitment to sustainability is embodied in our mission of “helping industry and the environment prosper.” Through our responsiveness, integrity and cost-effective solutions, we have enabled our clients to receive numerous awards and be cited among the leading greenest and financially performing companies.

For more information on CAPACCIO’s green team programs, please contact Julie Muszalski at jmuszalski@capaccio.com or visit http://www.capaccio.com. To learn more about Practice Greenhealth visit http://www.practicegreenhealth.org.

 

The EPA Considers Potential Revisions to its Risk Management Program Reply

On July 24th, 2014,the Environmental Protection Agency (EPA) published a Request for Information (RFI), soliciting public input on potential revisions to its Risk Management Program (RMP) with the goal of modernizing its regulations as mandated by the federal government under Executive Order 13650: Improving Chemical Facility Safety and Security. The ultimate purpose of the proposed rules is to prevent major chemical accidents such as the West, Texas explosion that occurred at the West Fertilizer facility on April 17, 2013. OSHA already issued a similar RFI on December 9, 2013 for its Process Safety Management (PSM) standard and while the EPA was not explicitly required to publish an RFI, its RMP regulation is so closely tied to PSM that the agency decided to act in parallel with OSHA.

Both the RMP and PSM regulations affect facilities with processes that utilize chemicals in quantities above established thresholds (both the EPA and OSHA developed threshold quantity lists). Facilities that fall under PSM or RMP must put in place a series of management systems and maintain certain required documentation, which are intended to improve chemical process safety and prevent catastrophes.

The EPA’s RFI requests much of the same information as OSHA’s, such as data on the economic impacts and safety benefits of amending the regulation. Both agencies are also considering adding new substances to their lists of regulated substances and adopting additional management system requirements. Proposed rules that may be of particular interest include:

•Requiring third party auditors for Compliance Audits
Like OSHA, the EPA is also considering requiring third-party auditors to conduct compliance audits, which are required at least every three years.The current requirement is only that at least one person “knowledgeable in the process” be part of the compliance audit team.

•Revising the scope of Mechanical Integrity to include safety-critical equipment
Mechanical integrity requires inspections and maintenance procedures of piping systems, valves, storage tanks, pressure vessels, relief and vent systems and devices, emergency shutdown systems controls (including monitoring devices, sensors, alarms, and interlocks) and pumps, but the EPA believes including safety-critical equipment will help improve chemical processing safety.

•Add stationary source location requirements to Process Hazard Analysis (PHA)
While facility siting must be addressed in a PHA, the EPA is considering expanding the specific requirements. For example, they are considering adding the establishment of buffer or setback zones to RMP requirements—these zones would be distances from the potential danger where it would be safe to house certain occupancies, such as control rooms, cafeterias, or contractor trailers. The idea behind this is to separate the public and other facilities from consequences of process incidents.

•Changing the criteria for Worst Case Release Scenarios to include quantities of aggregate vessels stored in close proximity
The RMP regulation currently requires facilities to determine the maximum quantity of a regulated substance release from a vessel, but does not require sites to take into account numerous small vessels of hazardous substances.

For a complete list of proposed RMP rules see the EPA’s RFI:

https://www.federalregister.gov/articles/2014/07/31/2014-18037/accidental-release-prevention-requirements-risk-management-programs-under-the-clean-air-act-section

The public will have until October 29th, 2014 to submit written comments online, http://www.regulations.gov (the portal for federal rulemaking), or by mail.
To view information on Executive Order 13650:

http://www.epa.gov/emergencies/eo_improving_chem_fac.htm

OSHA’s RFI for the PSM regulations can be found here:

https://www.federalregister.gov/articles/2013/12/09/2013-29197/process-safety-management-and-prevention-of-major-chemical-accidents

For more information, please contact Alex Wong Berman at 508.970.0033 ext. 126 or aberman@capaccio.com.

CAPACCIO Is Named As One of ZweigWhite’s Best Places to Work Reply

August, 2014 – CAPACCIO is proud to announce it achieved 6th place – out of approximately 500 environmental firms who entered across the US and Canada – in ZweigWhite’s Best Places to Work contest. ZweigWhite provides management information and expertise to architecture, engineering, planning, and environmental consulting firms worldwide. CAPACCIO, and this year’s other winners, will be officially announced and honored at ZweigWhite’s Hot Firm and A/E Industry Awards Conference on September 25-26, 2014.

The contest, which was based on anonymous employee surveys, was conducted by ELI Research, and recognizes the top architecture, structural engineering, civil engineering, environmental, and multidiscipline firms in the US and Canada. The results are based on questions regarding workplace practices, employee benefits, employee retention rates, and much more.

CAPACCIO’s vision includes being a great place to work, with a talented, energetic, and passionately engaged staff committed to the success of our clients and to each other. Toward this end, we foster an atmosphere for professional growth, innovation, teamwork, open-communication, and feeling valued, and are very excited to be recognized for our efforts toward this goal.

For more information, please visit:

http://www.zweigwhite.com/awards/best-firms-to-work-for/2014_winners.php