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.

 

Breaking News about Conflict Minerals! 1

 On Wednesday, August 22, the United States Securities and Exchange Commission (SEC) voted in favor of a rule for conflict mineral disclosure. Based on this vote, US-based manufacturing companies will  be required to publicly disclose the  use of conflict minerals (including tantalum, tin, gold, or tungsten) that have originated in the Democratic Republic of the Congo or  nearby areas. 

 Reporting to the SEC will be required on a new form (i.e., Form SD), if a company uses conflict minerals “necessary to the functionality or production of a product.” Companies will have until May 31, 2014 to make their first disclosures for the calendar year of 2013.

 This is two years in the making, as the Dodd-Frank Wall Street Reform and Consumer Protection Act was first signed into federal law in July of 2010. Continue to follow our blog for more information regarding conflict minerals and their now required disclosure.

View the SEC press release here: http://sec.gov/news/press/2012/2012-163.htm

Federal NPDES Stormwater Annual Site Inspections Due September 29 Reply

Have you conducted your Stormwater Annual Site Inspection?  Companies with coverage under the National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit for stormwater discharges associated with industrial activity must conduct an Annual Comprehensive Site Inspection by September 29, 2012.  The period for the inspection is September 29, 2011- September 29, 2012.  The annual comprehensive site inspection includes an inspection of the areas where industrial activity may be exposed to stormwater, and a review of corrective actions taken during the reporting period.  The Annual Reporting Form (Appendix I of the MSGP) must be mailed to the EPA within 45 days after completion of the inspection.

Companies covered under the 2008 MSGP must continue quarterly visual assessments, routine facility inspections, and required effluent or benchmark monitoring.  Results for quarterly benchmark monitoring must be submitted to the EPA within 30 days of receiving the results from the laboratory.

“No Exposure” Certifications obtained under NPDES regulations for stormwater permitting in 2007 are valid for five years and will expire in 2012. Companies should reassess whether the “No Exposure” conditions still apply and renew if applicable. Companies that have never filed a “No Exposure” Certification should consider whether their facility can meet the conditions of the certification, therefore precluding the need for coverage under the MSGP.

If you have any questions or need assistance, please call Lucy Servidio at (508) 970-0033 extension 114 or lservidio@capaccio.com.

EPA Updates to EPCRA Section 312 (Tier I and II Reporting) Requirements Reply

The US Environmental Protection Agency (EPA) has modified its Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II forms) with both new mandatory and optional data elements and updates to the Tier II form structure.

The following data is now mandatory on Tier I and II forms:

  • Reporting facility’s latitude and longitude
  • Identification numbers assigned under EPA’s Toxic Release Inventory (Form R reporting) program and Risk Management Program (if applicable)
  • Whether the facility is manned or unmanned and the maximum number of occupants present at any one time
  • Whether the facility is subject to EPCRA Section 302 (Emergency Planning Notification) and the Clean Air
    Act Section 112 (r) (Risk Management Program)
  • Contact information for the individual responsible for completing the forms and emergency coordinator for facilities subject to EPCRA Section 302
  • Owner/Operator and emergency contact email addresses

In addition to the above, the rule also revised the range codes for the maximum and average daily amount of the hazardous chemical at the facility and added optional data elements for facility phone number and parent company contact information.

EPA also made revisions specific to the Tier II form:

  • Added separate data fields for reporting pure chemicals and mixtures
  • Facilities must provide a description for storage types and conditions rather than reporting codes
  • Revisions to allow for reporting of additional state or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds

These changes are effective January 1, 2014 for reporting year 2013.  Forms for reporting year 2013 are due March 1, 2014.

Please contact Linda Swift at (508) 970-0033 extension 119 or via email at lswift@capaccio.com with any questions you may have regarding these changes.