Answers to Frequently Asked 527 CMR 33 Questions Reply

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 lswift@capaccio.com or Chris Walton at 508-970-0033 ext. 139 or cwalton@capaccio.com.

 

When to Notify the MassDEP Bureau of Waste Prevention of a Spill or Release Reply

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 lswift@capaccio.com with any questions you may have regarding reporting spills.

CAPACCIO’s Linda Swift to present 527 CMR 33 at CMBEN Reply

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 mhubbard@worcesterchamber.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 lswift@capaccio.com.

 

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)