Annual Rideshare Reports Due December 31, 2013 Reply

As you may be aware, the Massachusetts Department of Environmental Protection’s (MassDEP’s) Rideshare Regulation (310 CMR 7.16) requires facilities that meet certain criteria to complete and submit an annual Rideshare Report summarizing their rideshare program.

The criteria that must be met to be applicable to these requirements includes:

• Businesses with 250 or more applicable commuters that are subject to the MassDEP Air Operating Permit Program (310 CMR 7.00, Appendix C) or

• Businesses with 1,000 or more applicable commuters

• Educational institutions with 1,000 or more applicable students or applicable commuters combined

The definition of “applicable commuters” is employees that work 17 hours or more per week for 20 or more weeks per year; that commute to work between the hours of 6:00 a.m. and 8:00 p.m.; and use their vehicle for work purposes during work hours less than 5 times per month. “Applicable students” are students that are full-time commuting students and live off campus; are scheduled to begin and complete classes between 6 a.m. and 8 p.m.; and need their vehicle for class assignments or for after-school work less than five times per month.

For further details, please visit:
http://www.mass.gov/eea/agencies/massdep/air/programs/the-massachusetts-rideshare-program.html

If you meet the rideshare requirements, your annual report is due December 31, 2013.

What must you do if your business/educational facility meets the requirements?

• Collect data by surveying your employees/students current commuting patterns*
• Identify available commuting options
• Set goals and develop a plan for reducing drive-alone commute trips by 25 percent
• Offer options and incentives to reduce drive-alone commute trips
• Review how commuting patterns will change as a result

*This year is a short form year so a survey is not required; however, many companies choose to conduct a survey each year.

Many facilities find collecting rideshare data from employees a challenge. Capaccio has been helping clients make the process easier and more efficient. Using web-based forms we developed, Capaccio can host your custom commuter survey online and collect data in a database for easy analysis. The findings can be shared with employees online and also be tailored to report commuter trends for your environmental management system (EMS) objectives and targets and help facilitate the completion of your rideshare report. The tool may also be tailored to your facility’s internal programs where employee transportation has been identified as a significant environmental aspect in your EMS goals and targets. Please see our rideshare service sheet for more details or visit our website for our entire suite of services.

For more information on Capaccio’s rideshare services, please contact Dan Forsythe at (508) 970-0033 ext. 135 or dforsythe@capaccio.com.

Toxics Release Inventory Update Reply

2012 Toxics Release Inventory (TRI) Preliminary Dataset

EPA has posted the 2012 TRI preliminary dataset.
http://www2.epa.gov/toxics-release-inventory-tri-program/2012-tri-preliminary-dataset

Data can be searched by facility name, location, industry sector, or chemical name. TRI reported data is used by the EPA to update regional programs and goals from recent TRI data. Through this dataset, there is access to determine chemicals a particular facility is using and releasing, information on facilities initiating pollution prevention activities for the recent calendar year, whether a particular facility has reported to TRI and research on chemical released in the United States or a specific geographical area. The dataset contains reports processed as of September 3, 2013 and a complete dataset will be available in October.

Pollution Prevention Search Tool

The EPA offers the TRI P2 Search Tool, http://www.epa.gov/enviro/facts/tri/p2.html, which is a useful application that allows easy access to submissions of P2 information to find out what facilities are doing for pollution prevention. Searches can be filtered by industry, chemical, state and/or year, with a results page that populates the most relevant reports. This is a useful tool in TUR planning when evaluating toxic use reduction opportunities.

Electronic Reporting Required for TRI in 2014

A final rule was developed by the EPA requiring facilities to report all non-trade secret TRI data using the TRI-ME web online reporting application.
http://www2.epa.gov/toxics-release-inventory-tri-program/electronic-reporting-toxics-release-inventory-data-final-rule

This rule mandates that TRI forms are submitted electronically and applies to all facilities that are required to report to the TRI program. The rule becomes effective January 21, 2014. The TRI-ME web software can be found on the CDX database and will have new security measures for those that are certifiers of TRI forms.
http://www2.epa.gov/toxics-release-inventory-tri-program/tri-meweb-resources

CAPACCIO can assist with all of your reporting needs. Click here to view a complete list of Capaccio’s Hazardous Materials Management services or visit our website.

For more information on items contained in this article, please contact Travis Wheeler, CHMM, TURP, at 508.970.0033 ext. 115 or twheeler@capaccio.com.

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.