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.

 

 

Capaccio’s Cristina Mendoza Receives EBC’s Ascending Leader Award Reply

Capaccio Environmental Engineering, Inc. (Capaccio) is pleased to announce that Cristina Mendoza was selected as a 2017 Environmental Business Council (EBC) Ascending Leader Award recipient. The Award recognizes young, ascending professionals in the energy and environmental sectors who demonstrate exceptional leadership and industry involvement early in their careers. Recipients are also considered leaders within their respective companies, who manage high profile projects and provide mentorship to their peers. They are active in their communities both professionally and personally through leadership positions in business associations, non-profit organizations, and civic groups.

Ms. Mendoza is an Environmental Scientist at Capaccio, an award-winning, women-owned, 30-person environmental, health and safety consulting and engineering firm based out of Marlborough, MA. While still in college/graduate school, Ms. Mendoza began working as an intern at Capaccio and quickly demonstrated her capabilities and willingness to learn by assisting with several high profile projects.

In 2015, she was hired full-time as an Environmental Scientist/Sustainability Consultant and continued to further develop her knowledge and expertise in the sustainability arena. She also became involved with EBC’s young professionals and became a member of EBC’s Ascending Professionals Committee (Member since 2013 – Leadership Team Member since Summer 2014) and planned a program event on sustainable, responsible, impact investing. She also began serving as a member and facilitator of the Associated Industries of Massachusetts (AIM) Sustainability Roundtable, which plans and executes events throughout the year on sustainability topics.

In January 2016, she was promoted to the ES II level, and increased her responsibilities by also becoming the leader of Capaccio’s Sustainability and Systems group. In this role, she lends her technical expertise, ensures internal resource development, and facilitates technical group strategy. Her knowledge has been tapped in live presentations such as the 2017 SESHA (Semiconductor Environmental Safety and Health Association) Symposium where she presented on the topic of ‘The Power of Aligning EH&S with Business Aspirations’.

Ms. Mendoza holds a Bachelor of Arts in Environmental Science (2014) and a Master of Business Administration (MBA) (2015) from Clark University.

Other recipients of the award included Lauren Ballou, Environmental Planner, VHB; Kathleen Brill, Associate, Foley Hoag LLP; Heidi Lemieux, Senior Project Engineer, Sanborn, Head & Associates, Inc.; and Matthew Waldrip, Environmental Engineer, Eversource Energy. Recipients were honored on August 10 at the EBC Annual Summer Garden Party in Boston, Massachusetts.

Now in its 25th year, Capaccio lives and breathes its mission of “helping industry and the environment prosper” with a commitment to leading our industrial and institutional clients toward sustainable growth. Through our responsiveness, integrity and cost-effective solutions, we have enabled our clients to become among the leading greenest and financially performing companies. In 2016, CAPACCIO was named #1 Best Firm to Work For by Zweig Group. Visit us at www.capaccio.com or learn more about our total solution the EHS DashboardTM at www.ehsdashboard.com.

 

Management Systems Internal Audits – Going Beyond the Annual Physical Reply

EH&S Management systems standards are developed to proactively address and continually improve how to protect the environment and how to establish and maintain a safe and healthy workplace. The environmental management system, ISO 14001, and occupational health and safety management system, OHSAS 18001 – soon to be converted to the new ISO 45001, help to manage risks and take advantage of opportunities. Just as an annual EH&S audit can be related to an annual physical, internal systems audits can be related to the ongoing monitoring of your overall health. Working with a general practitioner to consistently improve a functional area of one’s health mandates a certain amount of effort. However, if this area is of highest risk to us, we will devote that time.

Commitment to internal auditing has huge potential for risk reduction and continual improvement, just as commitment to ongoing monitoring of your health. Part of this commitment is ensuring that your EH&S management system is functioning as intended to promote environmental protection and a safe and healthy workplace. Having an effective management system achieves this.

Management systems are most successful when all those affected in some capacity by the system embrace the procedures and best practices shared with them from the system – making the role of an internal auditor for management systems essential. They can act as another set of eyes to review operations and to act as the catalyst to best practices and improvement.

The internal auditor has the platform to point out an internal audit finding, such as emergency procedures not being executed as stated in documentation. They also have the responsibility to identify areas where there are opportunities for improvement, such as posting significant aspects in areas affected by those aspects to increase awareness.

In order to show continued improvement for an organization’s management system or an individual’s health, concrete evidence of steps taken to do so are very important. In a management system, objective evidence that procedures are being followed and are effective is a must-have. Internal audit findings are meant to take an organization’s EMS to the next level of best practices and demonstrate improvement of the system.

Having a management system, or working with a healthcare provider, won’t be of value if we simply carry on with business as usual. We cannot expect there to be improvements each time we have an annual appointment or audit without acting to correct or address issues identified. The value comes from embracing the guidance from the internal auditor or healthcare provider to see the most concrete improvements.

Embracing this guidance means continually improving the management system itself, and for this scenario, improving the preparation, execution, and documentation of internal audits. Managing audit documentation, corrective actions, and audit schedules in discrete, siloed, files leaves room for error and inconsistencies. Tools are now available to transform the way in which this is accomplished. A tool like the EHS-DashboardTM has the capability to schedule audits, log findings, communicate internally to address corrective actions, and store documentation, while simultaneously linking each piece together.

If you have questions about internal audits for management systems or how to implement tools to enhance your existing systems, please don’t hesitate to reach out to our experts. Linda Swift can be reached at lswift@capaccio.com or 978-621-6433 and Cristina Mendoza can be reached at cmendoza@capaccio.com or 774-249-2418.

August 7, 2017 – UST Deadline Reply

The August 7, 2017 deadline for closure of single-walled steel underground storage tanks (USTs) is rapidly approaching per the Massachusetts Department of Environmental Protection (MassDEP) UST Systems regulation 310 CMR 80.15. This regulation applies to all in-service and temporarily out-of-service USTs, with the exception of consumptive use tanks and tanks that were relined prior to August 8, 2007 in accordance with API 1631, 1983 Edition providing that the owner has a permit and approval from the Fire Department and a current, legally valid warranty for the relining.

At this juncture, if you are the owner of an UST that is not exempt from this regulation, the UST should have been or should be scheduled to be properly closed in accordance with MassDEP requirements. If not, you still have time to avoid MassDEP enforcement activity.  The MassDEP is granting extensions of the August 2017 deadline until July 1, 2018 to those who:

  • Take the UST out of service by August 7, 2017
  • File a Single-Walled Steel Tank Out-of-Service Notification to MassDEP within 30 days of the out-of-service date
  • Submit to MassDEP no later than August 7, 2017 a fully executed and signed contract for removing or closing the UST(s) on or before July 1, 2018

Remember that as part of the UST closure regulations, an assessment for contamination is required to be conducted upon in-place closure or, for removed USTs, within 24 hours after the UST is removed and prior to excavation backfill. The results of this assessment need to be reported in an UST Closure Report. Although the assessment is not required to be completed by a Licensed Site Professional (LSP), the UST removal contractor must be knowledgeable in the MassDEP release reporting criteria under the Massachusetts Contingency Plan (MCP). In all cases, if a reportable release condition is identified, an LSP must be involved in conducting remedial actions.

CAPACCIO’s EHS-Dashboard™ software solution can help you track regulatory deadlines associated with UST compliance as well as record monthly inspection data so that you can be ready to demonstrate compliance in real time. Please visit http://www.ehsdashboard.com to schedule a demo of our dashboard or contact Chris or Dawn whose contact information is listed below.

CAPACCIO is available to assist you in determining whether this regulation applies to you, assist you in meeting the August 7, 2017 deadline, and/or providing LSP services and assistance in the UST closure assessment process. Please contact Chris Walton, PE, PCEE at 508-970-0033 ext. 139 or cwalton@capaccio.com or Dawn Horter, PG, LSP at 508-970-0033 ext. 118 or dhorter@capaccio.com for additional information.