It’s hard to say no to a Super Hero… Reply

 

I’ve been 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 on May 3 2012. I’m following a presentation given in 2009 by Pam Eliason of the Toxics Use Reduction Institute (TURI) where she was introduced as having the answers to all of industry’s toxics use problems. I thought only a super hero could meet those expectations so I got myself a cape and now I am Super TURP ( Toxics Use Reduction Planner).

My super power is opening people’s minds to new ways of doing things. This results in using less toxic chemicals and generating less byproduct per widget manufactured. This mind bending ability can make companies more profitable and protect their greatest assets, their employees!

In order to prepare for my Australia presentation I attended a conference that  TURI held on April 12, 2012. I was interested in learning more about safer alternatives and attended the Green Chemistry track. I must confess, I had an ulterior motive to attending the conference. I wanted to get interviews with TUR Planners about their successes with TUR planning so that I could share them with the folks in Australia.

I decided to wear my Super TURP cape to the conference in order to get street cred, or maybe sympathy, from the crowd. It worked! I was able to get 10 companies to give me their input on what they think is the biggest benefit is to using the TUR planning process in their companies.

Please listen to the comments from Cindy Keegan, Manager, Environmental, Health& Safety Analogic Corporation and David Kiddo, Global Business Manager, Wire & Cable, Alpha Gary by clicking on each of the play buttons below.

Comments from Cindy Keegan

Comments from David Kiddo

Isn’t it great that Australia is looking to Massachusetts as a model for reducing cancer in the workplace? I’m proud to be representing TUR Planners and spreading the good word about the Toxics Use Reduction Act (TURA).

Need some assistance in making your company’s TUR Plan leap over tall buildings in a single bound…reduce payback periods…open up TUR Team minds to new ideas…we have a team of super heroes at CAPACCIO…just waiting to wear our cool capes!

Look for future blogs from down under …there will be photos with emus…maybe…Lucy

(Right) CAPACCIO’S Lucy Servidio with the Photofabrication Engineering TUR Team

CAPACCIO’s Travis Wheeler…Boy Wonder (Helping companies reduce the use of toxic chemicals)

Reminder: 2012 is a planning year under the Toxics Use Reduction Act (TURA) Reply

The letter was sent by Suzi Peck,  Director of the Toxics Use Reduction Program, Bureau of Waste Prevention, for the MassDEP

Facility Manager and/or Toxics Use Reduction Planners: 2012 is a planning year under the Toxics Use Reduction Act (TURA) and facilities covered by TURA are required to complete their TURA planning for this planning cycle by July 1, 2012. Last December, MassDEP sent a postcard alerting that notice to employees regarding the planning process was to be completed by January 1, 2011. Facilities that are required to submit a Form S for at least one chemical by July 1, 2012, and who have submitted a Form S for that chemical on a prior year, are required to complete one of three types of planning for the 2012 planning year:

Toxics Use Reduction (TUR) Planning
Resource Conservation (RC) Planning
Environmental Management Systems (EMS)

Toxics Use Reduction (TUR) Planning
If a facility has completed only one TUR plan and one TUR plan update, then the facility is required to develop a toxics use reduction plan or plan update, and to submit a TUR Plan Summary to MassDEP by July 1, 2012. In addition, if a facility prepared a Resource Conservation Plan in 2010, it must return to TUR planning for the 2012 planning cycle or integrate TUR planning into an Environmental Management System. Facilities that completed aResource Conservation Plan in 2010 are also required to submit a Resource Conservation Progress Report to MassDEP by July 1, 2012.

Resource Conservation Planning
If a facility has completed a TUR plan and two plan updates (i.e., completed TUR plans for three planning cycles), it may elect to prepare a Resource Conservation Plan for the 2012 planning year. Resource conservation planning is aimed at reducing energy, water, materials, or non-reportable chemicals. This option may be attractive to facilities that have succeeded in reducing toxics use and are looking for other opportunities to further environmental improvement and facility efficiency. If you choose this option, submit a Resource Conservation Plan Summary (instead of a TUR Plan Summary) to MassDEP by July 1, 2012, documenting your planning effort. In addition,if your facility did a Resource Conservation plan in planning year 2008, and completed a TUR plan and a Resource Conservation Progress Report in 2010, then you may return to Resource Conservation planning in 2012.

Environmental Management Systems
If a facility has completed a TUR plan and two plan updates (i.e., completed six years of TUR planning), it may integrate TUR into its Environmental Management System (EMS). This option allows companies that already have an EMS to integrate TUR into this more comprehensive system, thereby reducing duplication of effort. If you choose this option, then submit an EMS Progress Report to MassDEP by July 1, 2012 documenting that your EMS addresses toxics use reduction.

Plan Submittals due by July 1, 2012
Depending on which option you choose, a TUR Plan Summary, RC Plan Summary, or EMS Progress Report must be submitted to MassDEP by July 1, 2012. This means that all required planning must be completed before this date. MassDEP encourages facilities to file Plan Summaries online through eDEP, available at: www.mass.gov/dep/service/compliance/edeponlf.htm

Plan Certifications
TUR Plans must be certified by a MassDEP approved Toxics Use Reduction Planner. RC Plans must be certified by a
TUR Planner that also has specific training in resource conservation (see 310 CMR 50.63) and has been approved by
MassDEP to certify RC Plans. EMS Progress Reports must be certified by either a TUR Planner with training in EMS and approved by MassDEP to certify EMS plans, or by an EMS professional with training in TUR.

For more guidance on certification requirements, please consult the MassDEP web site at:
http://www.mass.gov/dep/toxics/approvals/turforms.htm#cert

If you do not have a certified in-house TUR Planner, you should consider hiring a general practice TUR Planner to guide you through the planning process. An updated list of certified Planners (as of February 2012) is available on MassDEP’s web site at:www.mass.gov/dep/toxics/tura/planners.htm

Guidance, Training, and Technical Assistance
Helpful web links for further guidance, training, and technical assistance resources include:

Regulations, Fact Sheets and Guidance: MassDEP
www.mass.gov/dep/toxics/laws/policies.htm

Continuing education training sessions on TUR planning, RC planning and EMS: MassDEP
 http://www.mass.gov/dep/toxics/tura/training.htm

This site includes links to training and workshops provided by the Toxics Use Reduction Institute, Office of Technical Assistance and Technology and MassDEP.

For questions or more information on TURA planning requirements please contact the MassDEP staff listed below:

Toxics Use Reduction Planning, Lynn Cain, lynn.cain@state.ma.us, 617-292-5711
Resource Conservation Planning, Lynn Cain, lynn.cain@state.ma.us, 617-292-5711
Environmental Management Systems, Cynthia Chaves, cynthia.chaves@state.ma.us, 617-292-5848

MassDEP Sewer Connection Permit Renewals Reply

The Massachusetts Department of Environmental Protection (MassDEP) promulgated new sewer system extension and connection regulations (314 CMR 7.00) in 2007.  These regulations required industrial facilities with wastewater discharges above certain thresholds to apply for a permit, submit a self-certification, or be considered “Permit by Rule” which does not require a submittal. The following thresholds determine what actions must be taken:

  • You discharge to an EPA approved industrial pretreatment program (IPP) and your combined discharge (industrial and sanitary) is greater than 50,000 gallons per day (gpd) – Apply for Permit
  • You discharge to an EPA approved IPP and your combined discharge (industrial and sanitary) is less than 50,000 gpd – Permit by Rule
  • You discharge to a non approved IPP and your combined discharge (industrial and sanitary) is greater than 25,000 gpd – Apply for Permit
  • You discharge to a non approved IPP and your combined discharge (industrial and sanitary) is less than 25,000 gpd – Submit a Compliance Certification

Both the permit and the self-certification are valid for 5 years.  With the majority of the final permits and certifications being issued and approved in early 2008 many industries will be required to renew their permits or certifications towards the end of this year.

The permit renewal process is the same as the process completed to obtain the original permit. Permit renewal applications (BWP IW 38 or 39) must be submitted 90 days prior to the expiration of the existing permit and companies will again be required to complete the public notification process. Self-certifications must be submitted before the existing certification expires and do not require any public notification.

If you have any questions about the MassDEP Sewer Connection regulations or the renewal process contact Bill Potochniak at wpotochniak@capaccio.com or 508.970.0033 ext. 134.

2012 Compliance Calendar Updated Reply

CAPACCIO provides a free annual compliance calendar to highlight the year’s deadlines for meeting regulatory requirements required by the MassDEP, the EPA and OSHA. Each item is explained in full detail and provides backup information to better understand what the requirement might entail.

The calendar was updated in February with the following changes:

  • Carbon Disclosure Project
    Three new reporting dates have been added to the compliance calendar. These dates are for the Carbon Disclosure Project’s (CDP) carbon, water, and supply chain reporting. If your company participates in the CDP, you may want to re-download the calendar to have these dates on your calendar.
  • Massachusetts Mandatory Greenhouse Gas Reporting
    The language related to Massachusetts Mandatory Greenhouse Gas Reporting has been modified. The original language stated that “If reporting year 2012 CO2e emissions were 10,000 pounds or greater, then reporting year 2011 emissions must be verified by December 31, 2012.” We have changed this language to: “If reporting year 2012 CO2e emissions were greater than 10,000 tons, then reporting year 2011 emissions must be verified by December 31, 2012.” Please re-download the calendar to capture this change or make a note of it.

CAPACCIO’s comprehensive compliance calendar is available in a Adobe PDF format which includes brief summaries of the various health and safety requirements mandated by OSHA in their General Industry Standards and any corresponding timelines. Or in a Microsoft Outlook (PST) format that can be imported into your existing Outlook calendar.

Download the Calendar Today:
http://www.capaccio.com/Resources/DLoads/AnnCal/dload_anncal.html