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.

EPA Haz Waste Generator Rule Updates Reply

The Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program was originally promulgated in 1980. Since that time, the EPA has become aware of the need for more clarity, consistency, and flexibility within the program. EPA’s final rule, which was promulgated on May 30, 2017, revises the hazardous waste generator regulations making them easier to understand, and providing greater flexibility in how hazardous waste is managed.

Some key provisions where EPA is finalizing flexibility are:

  1. Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed, and
  2. Allowing a very small quantity generator (VSQG) (previously called conditionally exempt small quantity generators) to send its hazardous waste to a large quantity generator under control of the same person.

This program update is also implementing some Improvements to environmental protection and, therefore, several of the revisions to the hazardous waste generator regulations are more stringent than those in the previous version. One such revision requires Small Quantity Generators (SQGs) to periodically re-notify the EPA regarding their generator status every four years (SQGs needed to only notify once under the previous system).

You may Click Here for additional information on the RCRA Program Updates.  Please note that though the Federal regulations are currently in effect, the Massachusetts Department of Environmental Protection (MassDEP) has indicated they will not be adopting these updates until 2018.

We can help! Capaccio has RCRA experts that can assist you with the reporting and planning challenges associated with Federal and state hazardous waste programs.  If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 ext. 142 or adallaportas@capaccio.com.

 

 

Why your wastewater treatment system may need a check-up Reply

Industrial wastewater treatment systems serve a key purpose by treating pollutants not capable of being handled by the local municipal treatment system. This helps to reduce pollution and cost to taxpayers to operate and maintain municipal collection and treatment systems.

Why would your wastewater treatment system need an Annual Checkup?

When you receive an annual physical, the doctor checks you for basic vitals…heart rate, blood pressure, body temperature, height and weight. A typical wastewater treatment system audit will perform the same function, ensuring that:

  • Permits are current
  • Facility is complying with the key portion of the permit
    • Sampling has been performed
    • Reports have been submitted
  • Regulations are met
    • 257 CMR 2 – Wastewater Grading/Staffing/Operator Certifications
    • 314 CMR 7 – Sewer System Extension and Connection (Permits)
    • 314 CMR 12 – Operation and Maintenance of the IWPS
    • 360 CMR 10 – MWRA Specific Requirements (if applicable)
    • Local regulations
  • System functioning as expected
    • Have alarms been triggered? If so, how frequently?
    • Have there been any discharge violations? Were they reported?

Provided there are not any obvious issues, the doctor (or the auditor) will generally give you the okay and send you on your way. But what happens when the issues are not so clear?  What happens when you complain of some neck and back pain?  Well, you get sent to a specialist where they perform more testing and review more specific symptoms.  The same can be true for a focused review of your industrial wastewater treatment system and programs…take it a step or two beyond the typical audit.

A more effective audit/review should include evaluating the treatment system periodically.

Many treatment systems are designed, installed, and rarely revisited during the lifespan of a facility. This can lead to a variety of lingering problems.  You can treat the symptoms (adjusting the existing treatment system) or you can rid yourself of the disease by addressing the problem causing those symptoms (updating the system itself).  Some problematic areas to review include:

  • Process changes affecting the system’s treatment ability
  • Out-dated controls
  • Alarm notifications when operator is not nearby
  • Lack of secondary containment around chemical addition equipment
  • Limited automation of the system– increasing operator difficulty
  • Manual log maintenance by the operator

Performing an engineering evaluation of your treatment system and identifying/prioritizing areas for improvement can help increase the ease of operation of the system, increase safety to the operators, proactively provide flexibility for future process/manufacturing expansions and improve compliance of the system. Consider the cost in lost production, if the wastewater treatment function was no longer operating.

Just like you need to take care of yourself with an annual check-up, your wastewater treatment system also needs TLC to keep it functioning properly.

As part of our 25th Anniversary, CAPACCIO is offering a free one-hour industrial wastewater treatment system review to ensure it is still performing as it should. These evaluations also provide TCHs for your operators.

To schedule your free evaluation, please contact Matt Melvin, PE, at mmelvin@capaccio.com or 508-970-0033 ext. 143.

Additionally, 2017 is also a TCH renewal year for wastewater treatment operators. Please visit our website at http://www.capaccio.com/services/training/wwt_index.html or contact Matt if you would like to enroll in any of our courses or obtain your TCHs through the free evaluation.

 

New OHS Standard ISO 45001: Progress Towards Finalization Reply

Each year, nearly 2.2 million workers die as a result of an occupational injury or illness. This statistic is burdensome to organizations and society as a whole. To encourage a strong occupational health and safety program, the International Organization for Standardization (ISO) has been working on the development of a new Occupational Health and Safety (OHS) Standard; ISO 45001. This standard aims to provide organizations with the framework to manage the prevention of work related injuries, illnesses, and deaths.

ISO 45001 has been drafted to include many of the same concepts set forth in OHSAS 18001. The main differences between the two standards is that ISO 45001 has a much stronger focus on the context of an organization and requires top management to provide leadership in the development, management, and tracking of their company’s OHS Management System. It is expected that OHSAS 18001 will be withdrawn once the new ISO 45001 standard is published. Organizations certified to OHSAS 18001 will need to transition to ISO 45001 within three years of its publication.

Currently the new OHS Standard is in its second draft. A preview of this version is currently available for review.  For the next four months, the OHS Standard will be undergoing the translation and ballot phase of the review process. If a Final Draft International Standard (FDIS) is not required, the new ISO 45001 standard could be published as early as November 2017. If a FDIS is required, publication could be pushed back to the second quarter of 2018.

For more information please contact Bob King at 508-970-0033 ext. 113 or bking@capaccio.com or Katie Grasso at 508-970-0033 ext. 134 or kgrasso@capaccio.com.

MANAGING YOUR EH&S RISKS THROUGH AUDITING IS LIKE GOING FOR YOUR ANNUAL PHYSICAL – First in a series of 5 Reply

What do you think when you hear the word “Audit”? How about “Annual Physical”?

Run, Hide, Panic, Ouch, …No Problem!

On the way to my annual physical, I was thinking about the similarities to having an audit. It is normal to feel a certain amount of stress when preparing for, or participating in, any type of audit, even one of your personal health. Yet, we still have to have our “check-ups”.  Why? One reason is so that we can identify and address smaller issues before they become bigger concerns.

By definition, an audit is “a systematic and independent examination.” The types of audits and reasons to conduct one are varied, but the value of having one can make a significant difference toward risk management and continual improvement of your Environmental, Health and Safety (EH&S) programs and systems.

What if we look at undergoing an audit much like we would an annual physical examination? Like your annual physical, EH&S audits should be scheduled periodically and some level of review should be conducted at least annually.

For Annual Physical, Doctor may: For EH&S Audit, Auditor may:
Check vitals to confirm within normal ranges:   weight, blood pressure, bloodwork Check key performance indicators, review metrics, compliance and conformance status
Confirm any medications continue to be at effective doses Review systems, procedures, training for effectiveness
Review any issues or concerns Identify areas of actual or potential non-compliance and/or system concerns
Confirm ongoing healthy diet and exercise activities occurring Corrective and Preventive actions
Discuss Preventive Measures to Avoid Future Problems Identify and benchmark against latest best practices

The audit should be more than the review of a checklist for compliance…it should diagnose the overall health of your EH&S program by checking:

  • Are basic metrics telling the true story of the health of your EH&S programs and systems, like tracking chemical usage and storage, energy usage, water usage, air emissions, incidents …is it accurate, effective and helping you maintain compliance and demonstrate improvements? Should you consider a more efficient way to track and communicate information to your team?
  • Are corrective action plans still timely and effective? Should you change your approach? Maybe the issue you were trying to fix is all set and now you need to refocus. How do you ensure that your team has found the root cause of the issue and has not just applied a band-aid that is only a temporarily fix? Does your 25-year old wastewater treatment system really have the capacity to handle the new process being relocated from New Jersey?
  • Are there any issues that you have been ignoring that you need to prioritize? Are you sure you don’t need that air permit in order for your company to grow?
  • Are there potential non-compliance issues brewing throughout your EH&S system, but you are so wrapped up in it you can’t see them? Has training become ineffective and reports been going in just a little bit late?
  • Are there new methods, technologies, or Best Management Practices that if you take the time to implement now would reduce risks in the future? Are you a “team of one” or has your team become isolated and doesn’t have the opportunity to share Best Management Practices?

Just as having routine “check-ups” take courage because you may hear things which result in changes to your life routines, it also takes leadership to examine your EH&S programs and systems. In the end, however, seeking feedback and looking for opportunities to improve will be beneficial for your company, your career, and your peace of mind.

Annual physicals help you reduce health risks and put you on a path for a better quality of life. An EH&S audit program directly supports risk management by providing an organization with data to prevent financial loss and reduce an organization’s EH&S risks.

Ideally, just as we hope our physical goes smoothly, there are times when we have to visit the doctor before we face a larger health issue. Similarly, an organization should also be prepared for an audit at any time; often through a combination of internal and external efforts to ensure processes continue to run smoothly. These efforts can come from many individuals and places, and it can be difficult to ensure accuracy, timeliness, and completeness of ongoing efforts. Consider a system like the EHS-Dashboard™ to store actionable information and organize findings. Completing proactive EH&S audits can ensure the effectiveness and efficiency of operations, the reliability and integrity of operational information, and compliance with laws and regulations. These factors can have a direct relationship to an organization’s financial performance and ability to meet its overall strategic goals.

Annual physicals often lead to referrals to specialists to focused areas of concern. Over the next few month’s CAPACCIO will provide eBlasts on different types of audits relating to focused issues to include ISO 14001:2015, process safety, wastewater treatment evaluations, and air permit assessments.

This won’t hurt a bit….

For more information, contact Lucy Servidio, CHMM, TURP, at 508-970-0033 ext. 114 or lservidio@capaccio.com or Colleen Walsh, CHMM, at 508-970-0033 ext. 129 or cwalsh@capaccio.com.