If your organization uses an aboveground storage tank (AST) with capacity greater than 10,000 gallons, you may have received a letter and an “AST Approved Standard Declaration Form” from the Department of Fire Services (DFS) and you may wonder why.
The form is not a cause for alarm, but DFS requires AST permit-holders to complete one form for each permitted tank and return the form to DFS.
To refresh memories, in 2016 the DFS standards were changed and now each permitted AST must be inspected and maintained in accordance with an “Approved Standard” – a standard proposed by the permit-holder and approved by the DFS. The Approved Standard you propose specifies the nature and frequency of the inspections you will perform for each tank.
As a holder of an AST Use Permit, organizations are responsible for ensuring the tank is inspected in accordance with an Approved Standard and that they maintain the records of inspections and maintenance performed in between renewals (Use Permits for ASTs renew every five years). As part of the renewal process, a Qualified Inspector (as defined in 502 CMR 5.03) must inspect the tank and review the tank inspection and maintenance records to ensure that the tank has been inspected and maintained in accordance with its Approved Standard. The findings of the tank inspection and documentation review are submitted to the DFS for review before the DFS will issue another Use Permit.
If you are an AST permit-holder, you may self-perform the inspections if you have a Qualified Inspector on staff. Otherwise you can retain an outside firm (e.g. an engineering firm, a tank supplier, or a chemical or industrial gas supplier) to provide the inspections and maintenance. CAPACCIO recommends that if you utilize an outside firm, make sure to obtain documentation after each inspection and confirm that maintenance action is performed to ensure employee safety and regulatory compliance.
Ensuring your organization’s AST tanks are being maintained in accordance with the Approved Standard is an important aspect in avoiding and mitigating risks and ensuring business continuity for your organization.
If you received one of these letters from DFS, make sure to pay attention to the due date at the bottom of the letter as some we have seen are due as soon as August 30, 2019.
At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EHS with your overall business objectives to strategically position you for success. Our unique approach combines our extensive EHS experience with innovative tools, such as our EHS DashboardTM, to effectively address your challenges. Our comprehensive solutions have resulted in award-winning EHS and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.