Could Your Hospital Benefit from a Gap Analysis? Reply

Do environmental, health and safety (EH&S) regulations at your hospital sometimes take a back seat to Joint Commission requirements? Is there ever confusion about which department is responsible for certain EH&S reporting and inspections? Do you feel like EH&S requirements may be slipping through the cracks? A gap analysis can help.

Capaccio recently conducted a gap analysis at a large Boston area hospital to determine what EH&S regulations were potentially being overlooked, or perhaps not assigned to anyone. The gap analysis was also able to show which of the hospital’s EH&S requirements were directly related to the Joint Commission elements of performance. In making this connection, the hospital greatly reduced the duplication of efforts by using existing programs already developed to meet the elements of performance.

Conducting a gap analysis is valuable because the hospital not only receives a list of all of its applicable EH&S regulations but also insight into how those requirements may link to Joint Commission standards. Furthermore, it provides an inventory of regulations that can be used to assign responsibility and ownership to help ensure that there are no surprises when the facility is inspected by a local, state or federal agency. This inventory can be taken one step further with a regulatory calendar that provides a detailed schedule of when submittals are due and permit renewals required. A gap analysis will make your facility run more efficiently, help ensure all EH&S requirements are being met, and also save both time and money.

To view a small sample of a regulatory matrix that would be delivered as part of the gap analysis click this link:
http://www.capaccio.com/handouts/Sample_H&S_Env_Matrix.pdf

To view a complete list of Capaccio’s Healthcare services, visit:
http://www.capaccio.com/Handouts/ServiceInfo/Capaccio_Services_Healthcare.pdf

For information on all of our service offerings, please visit our website at http://www.capaccio.com.

If you have any questions or would like additional information about our gap analysis services, please contact Bill Potochniak at 508-970-0033 ext. 134 or wpotochniak@capaccio.com.

Did you know – the fees you pay to MassDEP may have changed? Reply

Timely Action Schedule and Fee Provisions, 310 CMR 4.00 have been issued and may present changes to permit and compliance assurance fees relevant to you.

The Massachusetts Department of Environmental Protection (MassDEP) has been required to abide by emergency regulations which have increased fees in order to reflect the increase in the consumer price index since 2004. August 8, 2013 marks the effective date of these increases which apply to many MassDEP fee rates.

In order to ensure that correct payments are made, the link below provides updated tables incorporating the fee changes in the ‘Annual Compliance Fees’ and ‘Permit Application Fees’ links.

Links regarding updated topics such as ‘Fees, Billing& Timelines’, ‘Contacts for Fees and Billing Inquiries’, ‘Form for Fees & Payments’, and ‘Regulations for Fees & Payments’ can be easily accessed on this page as well.

http://www.mass.gov/eea/agencies/massdep/service/approvals/timely-action-fees-and-payments.html

For more information, please contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com.

EPA Reduces the Regulatory Burden for Industrial Facilities Using Solvent Wipes Reply

The U.S. Environmental Protection Agency (EPA) recently modified the hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA) to conditionally exclude solvent-contaminated wipes from hazardous waste regulations provided that the businesses clean or dispose of them properly. Based on EPA’s final risk analysis, the rule, peer reviewed in 2008 and published for public comment in 2009, concluded wipes contaminated with certain hazardous solvents do not pose significant risk to human health and the environment when managed properly. This common-sense exclusion will save industry up to $27.8 million per year.

Wipes are used in conjunction with solvents for cleaning and other purposes by tens of thousands of facilities in a variety of industrial sectors including printers, electronics, furniture, chemicals, automobile repair shops and manufacturers of automobiles.

The final rule excludes wipes that are contaminated with solvents listed as hazardous wastes under RCRA that are cleaned or disposed of properly. To be excluded, solvent-contaminated wipes must be managed in closed, labeled containers and cannot contain free liquids when sent for cleaning or disposal. Also, facilities that generate solvent-contaminated wipes must comply with certain recordkeeping requirements and may not accumulate wipes for longer than 180 days.

Please note, there is already a MassDEP policy on wipes located at this link:
http://www.mass.gov/eea/agencies/massdep/recycle/regulations/waste-and-recycling-policies-and-guidance.html

For more information about the EPA’s rulemaking visit:
http://www.epa.gov/epawaste/hazard/wastetypes/wasteid/solvents/wipes.htm

For more information or assistance, please contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com.

Hoisting Regulations Update Reply

On July 8, 2013 the Massachusetts Department of Public Safety (DPS) held a public hearing on proposed changes to the hoisting machinery regulation, 520 CMR 6.00. Many of the proposed changes reflect 2010 changes to the hoisting law, Massachusetts General Laws (MGL) Chapter 146, Section 53 and public comment from the December 8, 2012, public hearing.

520 CMR 6.00 requires that all operators of hoisting machinery complete an application and pass a test to obtain a license from the DPS. 520 CMR 6.00 is applicable to all hoisting machinery, including forklifts used on private or public property where the height of the lift exceeds 10 feet or the weight of the load exceeds 500 pounds.

The revised regulation includes an exemption of the MA hoisting license requirement for all operators if the company has a training program approved by the DPS and complies with the following requirements:

• A supervisory employee(s) who holds a hoisting license for the equipment being used must be on-site at all times during operation
• The company training program must be approved by the DPS biennially
• Authorized operators must be issued a company license that includes a picture of the employee, a list of hoisting machinery the employee is qualified to operate, and the name of signature of the supervisor who holds a license to operate that equipment. Employees can only be trained and certified to operate the specific equipment for which the supervisory employee holds a license issued by the DPS.

A facility seeking DPS approval of its training program must submit the following:

• A completed application form
• Copy of company curriculum and training materials (must include a classroom and practical component)
• A list of employees with hoisting license
• A list of type of equipment in use

The application forms referenced in the proposed regulation are not currently available from the DPS. At the public hearing, the DPS representative stated that all required materials will be posted on the DPS after the regulation is finalized. DPS did not provide an estimated date of when the proposed regulation will become final but Capaccio will post any updates on our blog once they are available.

The proposed regulation can be found here: http://www.mass.gov/eopss/docs/dps/engineering/inf-eng/520-cmr-6-redline-apr13.pdf

CAPACCIO can assist with bringing your company into compliance with this and other health and safety related programs. Please review our list of health and safety services.

For more information, contact Colleen Walsh at 508.970.0033 extension 129 or cwalsh@capaccio.com.