Deadline nearing for Hazardous Material Process or Processing (527 CMR 33) permit applications Reply

The new year is fast approaching, and so is the deadline to submit permit applications for 527 CMR 33 – Hazardous Material Process or Processing. On or before January 1, 2014, companies that fall under Categories 2 and 3 are required to submit their permit applications.

As a refresher, Category 2 companies have a process which involves or produces a hazardous material which occurs in a vessel that is greater than 2.5 gallons but less than or equal to 60 gallons. Companies that fall under this category must have the following in place in addition to submitting the permit application by the deadline:

• Hazard Communication Program
• Chemical Hygiene Program
• Flammable Storage Permit/License
• Emergency Response Planning

Category 3 companies have a process which involves or produces a hazardous material which occurs in a vessel greater than 60 gallons but less than or equal to 300 gallons, or a process that is conducted in an area that is classified as an H-occupancy per the Massachusetts Building Code. Companies that fall under this category must fulfill all the same requirements as Category 2, but must also have in place a:

• Process Hazard Evaluation for each Category 3 process
• Procedure for Post Incident Analysis

CAPACCIO has successfully helped companies come into compliance with this regulation and has worked with local fire departments to obtain the necessary permits. It is important that you are prepared to educate the fire department about your processes and that you involve them early in the process. If your permit is denied, the fire department may require an evaluation by a third party.

With the deadline drawing near, CAPACCIO can ensure that all the necessary leg work is done and the last minute details are taken care of before submitting your permit application to the fire department. We can help with determining your applicability and process category, updating your plans and policies, implementing applicable program requirements, compiling and preparing specific documentation to demonstrate compliance to the regulation, preparing your permit, and working with your local fire department to submit your permit.

Please contact Christopher Walton, PE, BCEE, Senior Associate, at 508.970.0033 ext. 139 or cwalton@capaccio.com if you require assistance on some or all of these tasks to ensure you meet the January 1 deadline.

Answers to Frequently Asked 527 CMR 33 Questions Reply

CAPACCIO has played a part in helping to clarify questions about the 527 CMR 33 Hazardous Materials Process or Processing Regulation by submitting questions to the Board of Fire Prevention.  Answers to our questions, as well as answers to questions from others, are available on the Massachusetts Department of Fire Services website at this link:  http://www.mass.gov/eopss/docs/dfs/osfm/cmr/527-cmr-33-faq.pdf

For more information or if you need help complying with this regulation, please contact Linda Swift at 508-970-0033 ext. 119 or lswift@capaccio.com or Chris Walton at 508-970-0033 ext. 139 or cwalton@capaccio.com.

 

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.

 

EHS Roundtable covering 527 CMR 33 scheduled for Friday, March 30 1

The Devens EcoEfficiency Center is holding an EHS Roundtable on Friday, March 30 to provide an overview of the new Massachusetts Department of Fire Services (DFS) Hazardous Materials Processing regulation (527 CMR 33) and discuss its development. Presenters will be Tim Rodrique, Director of the Division of Fire Safety within the State Fire Marshal’s Office and a focal driver of the regulation within the MA Board of Fire Prevention Regulations (BFPR), and practitioners with experience reviewing and facilitating process hazard analyses (PHAs) and Process Safety Reviews (PSRs) for clients in industrial plants and high technology academic research institutions.

The presenters will explain the differences from the process safety management (PSM) standard from OSHA and USEPA risk management plan (RMP) requirements. Presenters will also discuss some of the most important requirements and responsibilities contained within the Hazardous Material Process regulation and describe the current schedule for its implementation in the Commonwealth. After the presentation there will be time to respond to questions.  

On February 3, 2012 the new 527 CMR 33 came into effect.  DFS developed this regulation to help prevent the occurrence of incidents like the explosion in Leominster in 2005, the fire and explosion in Danvers in 2006, and the fire and explosion in Middleton in 2011 – all involving processes using hazardous materials.

Capaccio Environmental Engineering’s Linda Swift and Geoff Gilbert have been closely tracking the development of this new regulation and will be in attendance.   If you are unable to attend, but have questions or concerns about this regulation and how it might impact your operations, please post  your question in the comment section of this blog, or e-mail Linda or Geoff directly at lswift@capaccio.com or ggilbert@capaccio.com.

The meeting will be at:
33 Andrews Parkway, Devens, Conference Room 1
Registration fee is $15. Coffee and bagels will be available
RSVP donaneely@ecostardevens.com or 978-772-8831 x3304