Gray is the New Green Blog Series #2: The Caped Crusader Returns! Reply

Lucy with Cape

Lucy Servidio donning the Super TURP Cape in 2012

It was six years ago that I was in Australia speaking to the Western Australian Cancer Council about the benefits of Toxics Use Reduction planning. CAPACCIO was asked to be the keynote speaker and present industry’s perspective and approach to TUR planning.  I remember feeling I had to share examples of both practical and amazing success stories so that those attending the conference would be motivated to “take-off” on their own TUR journeys and reap the benefits that we have seen from working on TUR Plans with our clients. How would I capture their attention…what would make them believe me…that’s where the “Cape” comes in…I came up with the “SUPER TURP cape” to have a schtick for my presentation… the truth is the folks who organized the conference said when they first saw me in the cape they thought “Who is this wacko we flew in from America”?  See, I got their attention! All in all, I was well received and helped spread the TUR Planning seed to the lower hemisphere.

back view TURP cape 2

CAPACCIO’s visit with the South Korean delegation on April 13

So CAPACCIO was thrilled when we were approached by the South Korean Ministry of Environment recently to meet with a delegation of 22 representatives from the ministry and corporations including Samsung, LG Chem, and Hyundai to discuss our experiences in developing TUR plans for our clients. South Korea will be enacting a TURA-like regulation which will become effective in 2019. They have decided to implement this regulation to reduce the amount of chemical accidents and to improve worker safety and health. They chose to visit us because CAPACCIO has six TUR Planners, more planners per square inch than any other firm in Massachusetts!

lucy and cape

Bongwoo Shin and Lucy Servidio

When the delegation arrived, our panel of TUR Planners was ready for their questions. It was so cool to be speaking to businesses from across the globe and realize how much we have in common and how much we can learn from each other. We made a real connection…for example, CAPACCIO’s mission is “Helping Industry and the Environment Prosper.” LG Chem, one of the delegates’, mission is “Balance between Business and Safety, Health and Environment,” which of course is very similar.  We sealed the new friendship when the Director of the Chemical Safety Management Team, from the Ministry of Environment, Bongwoo Shin, asked if he could don the official “Super TURP cape”. Others tried it on too. Who knows maybe a purple cape will lead to CAPACCIO helping with TUR Plans in South Korea! As I have said                                                                 before, “It’s hard to say no to a SUPER HERO!

At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success.  Our unique approach combines our extensive EH&S experience with cutting edge technologies, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients.  To learn more visit us at www.capaccio.com.

 

Capaccio educates delegation from South Korea on Toxics Use Reduction planning Reply

group outside fists_cropped

The South Korean delegation and Capaccio TURP planners celebrate a successful meeting with a banner designed by the delegation

Marlborough, MA – Capaccio Environmental Engineering, Inc. was delighted to host a delegation of business and environmental leaders from Seoul, Korea at our offices in Marlborough last Friday. The stop at Capaccio was part of the groups’ tour of the United States and Canada to learn about best practices for chemical safety and the reduction of toxic substances. Toxics Use Reduction has become a focus for this group as South Korea will be enacting similar regulations to the Massachusetts Toxics Use Reduction regulations.

Capaccio was chosen by the Ministry of Environment Korea to sit down with the group due to our expertise with the Massachusetts Toxics Use Reduction Act (TURA) regulations and for our long history of developing Toxics Use Reduction (TUR) plans for a variety of clients in a variety industries. We also employ the largest staff of certified TUR Planners at one company in the state.

start-of-meeting.jpgDuring the meeting, Capaccio’s TUR Planners shared their expertise, best practices, industry examples, and techniques with the South Korean participants through their translator. The exchange between Capaccio and the delegates was very rewarding for both sides, and culminated with a picture outside with a banner designed by the Korean delegates.

lucy and capeThe group enjoyed wearing Senior Vice President, Lucy Servidio’s, Super TURP cape, which she had made when 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 in 2012.

Capaccio’s TUR Planners assist a variety of companies and industries with researching and identifying TUR options applicable to their operations, and evaluating technical, economic, social, and regulatory feasibility of options which will reduce the use of hazardous substances. We can also perform a check-up on how previously selected TURA options are working, and which ones may need a reexamination to help you reach TUR goals. Capaccio has a solution to help you manage your data (be it for reporting or to managing other EHS data).  Email Alexis Dallaportas or call her at (508) 826-1789 to learn more about TUR options, or how Capaccio’s EHS DashboardTM can help you manage your data for future reporting.

At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success.  Our unique approach combines our extensive EH&S experience with cutting edge technologies, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients.  To learn more, visit us at www.capaccio.com.

How are you doing with your TURA goals? Is it time for a check-up? Reply

 

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.

 

 

2016 Hazardous Waste and Hazardous Materials Reporting Deadlines Announced Reply

2016 will be here before we know it. With the New Year comes a series of compliance reporting deadlines, especially for companies that generate hazardous waste and store and use hazardous materials.

 Toxics Use Reduction Plan Employee Notification – due January 1

Massachusetts companies subject to Toxics Use Reduction (TUR) planning must post a TUR Plan Employee Notification requesting ideas on how to reduce toxic chemical use and waste generation by January 1, 2016.  Please note: The Employee Notification is also required for Resource Conservation (RC) Plans; however for RC Plans, the focus is on the asset chosen for the plan.  There is no Employee Notification requirement for companies that decide to incorporate TUR planning in its Environmental Management System (EMS). 

EPCRA 312 Tier II Reports – due March 1

Federal Emergency Planning and Community Right-To-Know Act (EPCRA) requires that facilities which store chemicals above the threshold planning quantities report those chemicals on a Tier II report annually to the State Emergency Response Commission (SERC) which in Massachusetts is the Massachusetts Emergency Management Agency (MEMA), the Local Emergency Planning Committee (LEPC), and the local fire department. Reports are due March 1, 2016.

Companies having to submit Tier II reports must include, among other information, the exact quantity of each reportable chemical stored at its facility and transportation information for EHSs. In order to provide this data, companies must keep accurate chemical storage inventories to quantify maximum and average amounts of chemicals stored at any one time for the previous calendar year.

The link to guidance regarding the data required by the Commonwealth of Massachusetts for Tier II reporting is http://www.mass.gov/eopss/agencies/mema/emergency-info/haz-mat/serc/

The state contact for information regarding the MEMA requirements for Tier II reporting is

Jeff Timperi at Jeff.Timperi@state.ma.us or (508) 820-2019.

MEMA is requiring Massachusetts facilities to use the online Tier2Manager reporting system for RY 2015.  Information on setting up an account and accessing facility data can be found on the MEMA website at:  http://www.mass.gov/eopss/agencies/mema/emergency-info/haz-mat/serc/

MEMA strongly recommends that companies include a site plan with Tier II reports.  Some LEPCs require site plans, so it’s good to check with them before you submit the Tier II.

Be sure to contact your LEPC and local fire department as well to inquire about any special requirements they may have regarding Tier II Reporting.

The EPA software is available at this link:

http://www2.epa.gov/epcra/tier2-submit-software

Massachusetts Recycling Permit Annual Reports – due March 1

Massachusetts Department of Environmental Protection (MassDEP) requires generators who recycle hazardous wastes under one of MassDEP’s Recycling Permits to report recycling activities for the previous calendar year on a MassDEP form by March 1, 2016. The MassDEP website for hazardous waste reporting and the annual reporting form for hazardous waste recyclers can be found here: http://www.mass.gov/eea/agencies/massdep/recycle/hazardous/periodic-hazardous-waste-reporting.html.

Federal Hazardous Waste Biennial Reports – due March 1

Large Quantity Generators of hazardous waste must file reports by March 1, 2016 which will include a summary of hazardous wastes generated in CY 2015.

The Hazardous Waste (HW) Biennial Report software and forms are now available for 2015 and can be downloaded from http://www.capaccio.com/Resources/Links_Regulatory.html.

The 2015 version of the software must be used to complete and submit the forms. The following must be mailed to the MassDEP:

  • A signed copy of the Federal 8700/12 Site Identification form, and,
  • The report’s SI, GM, and WR files either as exported from the software or in the EPA Biennial Report Flat File format copied to a CD

Massachusetts TURA Form S Reports – due July 1

MassDEP requires filing of Form S reports for companies otherwise using, processing or manufacturing listed toxic chemicals in excess of certain thresholds within the calendar year in addition to the federally required EPCRA 313 Form R reports by July 1, 2016 for toxic chemicals used during CY 2015.

For access to Form S go to: http://www.capaccio.com/Resources/Links_Regulatory.html. Please note, the forms will not be available for download until April, 2016.

  • MassDEP currently lists the following high hazard substances (HHS) with a lower reporting threshold of 1,000 pounds: trichloroethylene (TCE), cadmium and cadmium compounds, perchloroethylene (PCE, perc), hexavalent chromium compounds, formaldehyde, and methylene chloride.
  • MassDEP has added the following HHS for 2016: 1-boromopropane (n-propyl bromide, nPB), hydrogen fluoride, cyanide compounds, and dimethylformamide (DMF).  The reporting threshold will be 1,000 pounds for these chemicals.  Facilities should begin keeping usage records for these chemicals during 2016.  These chemicals will be reporting on the TURA Form S in 2017.

Massachusetts TUR Plans Recertification/Alternative Plan and EMS Options – due July 1

  • Massachusetts facilities that are subject to Toxics Use Reduction Act (TURA) Form S reporting must prepare/update its TUR Plans and submit plan summaries by July 1, 2016 with its Form S reports for calendar year 2015.
  • If a facility has a TUR Plan that has been through two recertification cycles, it has other options in addition to the traditional TUR planning process. For guidance see http://www.capaccio.com/Resources/Links_Regulatory.html.
    • A company can incorporate the TUR planning process into an already established EMS that has been through one full audited cycle. There are some very specific requirements that require the TUR chemicals to be listed as significant impacts in the EMS.  If this option is chosen, then the company does not have to maintain a traditional TUR Plan anymore.  However, it must submit a progress report by July 1, 2016, signed by either a TUR planner with EMS training or an EMS professional with TUR training.
    • Resource Conservation (RC) Plans allow companies to “take a break” from traditional TUR planning for a two year cycle, and then return to TUR planning every other planning cycle. Instead of focusing on the planning of the reportable TUR chemicals, the company can choose one of five assets.  The five assets include energy, water, solid waste, TUR chemicals that are under the reporting threshold, and chemicals that are exempt under TURA that are in articles or are of significant concern to the company.  The planning process for RC Plans is very similar to traditional plans.  Companies who developed an RC Plan in 2014 will have to submit an RC Plan progress report by July 1, 2016.  The plan must be certified by a TUR planner with additional training in RC planning. 

Federal EPCRA 313 Form R Report – due July 1

EPA requires annual filing of Toxic Release Inventory (TRI) Form R reports by facilities that manufacture, process, or otherwise use listed chemicals above certain thresholds.

Form R reports are due July 1, 2016 for chemical releases during CY 2015.  For access to Form R go to:  http://www.capaccio.com/Resources/Links_Regulatory.html.

The method for reporting TRI forms is to use the TRI-Made Easy Web (TRI-ME web) application via the Central Data Exchange (CDX) and the internet located at https://cdx.epa.gov/CDX/Login.

TURA Reporting Fee and Worksheet – due September 1

Toxics Use Reduction Act Fee – Facilities that are subject to Toxics Use Reporting (Form S Reporting) must submit a copy of the Toxics Use Fee Worksheet and fee by September 1, 2016.

CAPACCIO can assist with any or all of your reporting needs. Contact Lucy Servidio at 508-970-0033 ext. 114 or lservidio@capaccio.com or Colleen Walsh at 508-970-0033 ext. 129 or cwalsh@capaccio.com for more information. We’re here to help!