Our series about auditing and how it resembles an annual physical comes to an end
with this article that discusses risk management and process safety management
(RMP and PSM) assessments. In the same way that an annual physical may alert
you of weight gain or poor nutrition, an annual assessment of your chemical
processes provides a grasp of the current state of the management of your
An annual physical typically begins with a weigh-in. Your weight is tracked and observed by your doctor, and when unhealthy dietary choices and lack of exercise
have led you to pack on some pounds, your doctor will suggest that you modify
your food choices and increase your activity level.
Likewise, mismanaging your RMP and PSM program could lead your processes
down a slippery slope of poor condition. Does your maintenance group maintain
each part of your process in a way that prevents known hazards? Have your
operating procedures been reviewed and certified as current and accurate each
year? Is your frequency of training your employees on RMP and PSM often enough
so that employees are refreshed on the hazards of the process and can perform
their jobs in a safe manner? Answers to these questions are asked during a required
and enforceable 3-year Compliance Audit; however, wouldn’t it be a good idea to
catch these issues ahead of time by performing an annual program assessment?
These pieces to the healthy PSM and RMP puzzle need constant attention, review,
and care. Just as easily as you can get out of the exercise groove, you can also fall
off the wagon with your awareness and upkeep of your PSM and RMP processes.
An annual program assessment is non-enforceable, kept internal, and ensures
that you regularly evaluate your PSM and RMP targets for compliance, the plan
to reach those targets, program milestones achieved, the resources available
to get to the next step, and program areas in need of work.
Just like there are apps to track your food and exercise plan on your phone,
computer, or other electronic device, CAPACCIO’s EHS Dashboard can help you
track your PSM and RMP action items from an annual assessment to help you
reach your goals for a safe and healthy process.
Don’t wait for an inspection to uncover your program’s health issues; call or
email Christine Silverman 508-970-0033 x 127 or firstname.lastname@example.org
The Central Massachusetts Business Environmental Network (CMBEN) in partnership with the Worcester Regional Chamber of Commerce present ISO14001:2015 Are you Ready for the Changes?
When: Tuesday, September 12, 2017, 9:00 – 11:00 A.M.
Where: Saint-Gobain-Norton Hall, 1 New Bond St, Worcester, Massachusetts
The following are the speakers and the topics they will present on:
–Linda Swift of Capaccio Environmental Engineering, Inc. will speak on changes from ISO 14001:2004 to ISO 14001:2015
-Cristina Mendoza of Capaccio Environmental Engineering, Inc. will speak on specific areas that companies are having a difficulty understanding (e.g., context of the business)
Pam Eliason of TURI will give a short presentation on how these changes affect the EMS Alternative to traditional TUR Planning
Networking will be from 9:00 to 9:30 and the program will begin after that.
To register e-mail Isabelle Lavigne from Irwin Engineers at email@example.com, or call her at (508) 653-8007 ext. 10. Although there is no cost for this meeting, seating is limited so please register soon, and no later than September 8th.
For more information, contact Lucy Servidio at 508-970-0033 ext. 114 or firstname.lastname@example.org.
By July 1, 2017, each Large Quantity Toxics User of chemicals in the state of Massachusetts was required to file an annual toxics use report that included a Massachusetts Form S for each TURA listed chemical they manufactured, processed or otherwise used above applicable thresholds during 2016.
Companies subject to this reporting are required to pay annual toxics use fees. A fee worksheet/invoice was generated as part of your eDEP TURA report. This worksheet/invoice serves as your first notice of payment due. The fee must be paid in full by September 1, 2017.
In order to avoid late fees, don’t forget to print your worksheet/invoice, and send a copy with your check to:
PO Box 4062
Boston, MA 02211
Please note that if payment is not received by September 1st, a second invoice including a $1,000 late fee, will be sent.
If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 x142 or by cell at 508-380-6716.
Each company subject to the Toxic Use Reduction Act (TURA) is required to prepare a Toxics Use Reduction (TUR) Plan every other year. As the most recent TURA Plans were prepared for July 1, 2016, and your next evaluation efforts and updates are due July 1, 2018, we are now just past the mid-point of the planning cycle. That means that this is a great time to perform a check-up on the targets and objectives you planned for, and to see how are you doing with the TURA options your company intended to implement!
This is also a good time to take a look at the chemicals the TURA Administrative Council has designated as Higher Hazard Substances (HHSs) since the last planning year. Effective January 2016, n-Propyl Bromide, Hydrogen Fluoride, Cyanide Compounds and Dimethylformamide have been designated as Higher Hazard Substances. Under this designation, Massachusetts facilities with 10 or more full time employee equivalents that manufactured, processed or otherwise used 1,000 pounds or more of these chemicals per year, were required to report on their use in 2017, and are required to conduct toxics use reduction planning for them in 2018.
Capaccio can help! We have several experienced Toxic Use Reduction Planners that can help you evaluate what options are available to you that will reduce the use of these new HHSs, as well as to perform a check-up on how your previously selected TURA options are working, and what ones may need a reexamination to help you reach your TUR goals. If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 x142 or 508-380-6716.