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Breakfast Seminar Series
Environmental, Health & Safety Regulatory Updates
IntroductionsSeptember 20 Taunton MassSeptember 27 Framingham Mass
Wayne E. Bates, PhD, PE, Principal Engineer
Agenda
Firm Overview
■ Multi-disciplinary Consulting Firm Founded in 1911■ Full Service Capabilities: 280 Person Staff■ Employee Owned■ 8 Offices in MA, CT, NH and NY
Geographic Coverage
Tighe & Bond Full Service Capabilities
Civil Engineering
•Dams & Levees•Geotechnical Engineering
• Infrastructure•Land Use Planning•Low Impact Design•Parking & Circulation•Site Planning & Design
•Transportation
Environmental Consulting•Brownfields•Demolition & Asbestos/ Hazardous Materials
•Environmental Permitting & Planning
•Fuel Storage•Health & Safety•Regulatory Compliance
•Site Assessment & Remediation
•Wetlands and Ecological Services
Building Services •Geotechnical Engineering
•Electrical & Mechanical Engineering
•LEED Green Design•Owner’s Project Manager
•Structural Engineering
Technology •3D Modeling•GIS
Sustainability•Energy & Resource Conservation
•LEED Green Design•Low Impact Design•Renewable Energy
Environmental Engineering•Drinking Water•Solid Waste•Stormwater•Wastewater
Today’s Presenters
Bill Potochniak, PE Dave Horowitz, PE, CSP Doug Stellato
Brian DayJeff Bibeau, REM, TURPWayne Bates, PhD, PE
Today’s Program
■ Regulatory Experts■ Actively engaged in professional societies■ Regulatory awareness/involvement ■ Reputation with regulators■ History of helping clients ■ Breadth or expertise and certifications
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
David P. Horowitz, P.E., CSP, Project Manager
Slideshare: dphorowitzTwitter: @dphorowitzYoutube: dphorowitz
Tanks & Hazardous Materials Storage
Agenda – Regulatory Updates
■ Tanks and Hazardous Materials Storage■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health
Regulatory Updates – Tanks (Above ground)
■ 502 CMR 5.0– Tanks >10,000 capacity
storing any fluid other than water
– Regulation Changes» April 2015» Consistency with national
standards– EPA– West Virginia– New York
» 5 year versus 1 year permits
» Inspectors propose test protocol
Regulatory Updates – Tanks (Underground)
■ MassDEP’s new system for managing UST data– Requires the person responsible for updating the information to
submit a Proof of Identification (POI) form to MassDEP.
– We recommend creating an account first, then submitting the form – otherwise it will go into a pile of “orphan” forms and will likely take longer to be processed.
Planning for 2017– Tanks (underground)
■ Included in the January 2015 UST regulation update– Sumps & Spill Buckets - hydrostatic or
pressure testing no later than 1/2/2017
» Spill buckets need to be retested every 5 years
» Sumps are one-time tests
– Compliance Certifications due 18 months after a Third Party Inspection.
Top Five Things Regulators Look For
1. 18 month mid-cycle for certification (USTs)– 30 Day Return to Compliance
2. Managing sumps & spill buckets (USTs)
3. A/B/C Operator coverage (USTs)
4. Financial Assurance (USTs)5. Proposed inspection
protocols (ASTs)
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Doug Stellato, Project Compliance Specialist
Hazardous Materials
Agenda – Regulatory Updates
■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health
Regulatory Updates – Hazardous Materials
■ Tier II Reporting– 10,000 pounds– EHS substances– Tier II Manager
■ Chemical Control Laws– Alphabet Soup of Regulations– Updated Frequently
■ TSCA– June 2016 Update– Evaluate existing chemicals– Risk-based safety standard– Improved public transparency
Planning for 2017– Hazardous Materials
■ Tier II – March 1, 2017– Tier II Manager upload of facility– Consultant Access
■ CA Prop 65– Updated frequently
■ SVHCs– Updated in June and December
■ Supply chain driven– Products imported into Europe– Conflict Minerals
■ Preparing or reviewing Safety Data Sheets– Section 15 information
Planning for 2017– Hazardous Materials
■ TSCA– New Inventory rule
» Proposed by December 2016» New rule by mid-2017» 10 years of reporting
– New chemicals approved prior to going to marketplace– Mercury compounds export ban September 2016– New review process will rely on chemical use
Top Five Things Regulators Look For
■ #1 Accurate Inventory– Inaccurate amounts can lead to issues with other programs
■ #2 Site Diagram– Shows location of each reportable chemical
■ #3 Up-to-date SDS– Purchased and manufactured substances
■ #4 Testing Data– For chemical concentrations
■ #5 Maintain Import & Export Records– Is a broker being used?
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Jeff Bibeau, REM – Principal Compliance Specialist
Toxics Use Reduction
Agenda – Regulatory Updates
■ Agenda– TURA Applicability– TUR Amnesty Expiration– New High Hazard Chemicals– 2017 TUR Action Items– Top 5 TURA Compliance Items
TUR Applicability
■ List of Reportable Chemicals■ Use, Process, or Manufacture > reporting
threshold■ 10,000 and 25,000 reporting threshold■ Annual reports due July 1st
■ TUR Plan Update due every 2 years July 1st
■ TURA fee due to DEP September 1st
TUR Amnesty
■ Mass DEP issued an enforcement amnesty effective April 9, 2015 thru June 30, 2016
■ Voluntary disclose past TUR reports (Form S) and plans
■ Companies maybe unaware of the TUR requirements or may have inadvertently missed reporting one or more chemicals
■ DEP will be conducting Desk-Top Audits
Regulatory Updates – TURA
■ 5 Chemicals that will be Higher Hazard Substances (HHS) reporting in 2017
■ HHS Threshold: 1,000 lbs for chemicals manufactured, processed, or otherwise used in a calendar year – dimethylformamide (CAS# 68-12-2)– toluene diisocyanates (listed as: 2,4-TDI [CAS# 584-84-9]; 2,6-
TDI [CAS# 91-08-7]; and TDI mixed isomers [CAS #26471-62-5])
– hydrogen fluoride (CAS# 7664-39-3) – cyanide compounds (Chemical Category N106) – 1-bromopropane (n-propyl bromide (CAS# 106-94-5))
Planning for 2017
■ Reporting Season
– File Form S reports to Mass DEP (July 1st)
– Issue TURA fee to Mass DEP (September 1st)
Top Five Things Regulators Look For
■ #1 Reporting– Review listed chemical usages (were reports filed)
■ #2 Planning– Review required TUR Plan elements and support documentation
■ #3 Plan Certification– Plan must be signed by a Certified Planner
■ #4 Report & Plan Documentation– Calculations, SDS, manifests, basis for assumptions
■ #5 Past Reporting Obligations– Review of past chemical usage
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Jeff Bibeau, REM – Principal Compliance Specialist
Hazardous Waste
Agenda – Regulatory Updates
■ Hazardous Waste Determinations■ Hazardous Waste Management■ State Regulated Hazardous Waste■ 2017 Hazardous Waste Action Items■ Top 5 Hazardous Waste Compliance Items
Hazardous Waste
■ RCRA v. State of Massachusetts
■ Listed Wastes (A List in the Regulations) - or –
■ Characteristic Hazardous Waste exhibits one or more of the following characteristics:– Ignitability– Corrosivity – Reactivity– Toxicity
■ All businesses are required to perform a Hazardous Waste Determination on the waste they generate to identify whether or not that waste is hazardous.
– Initially and Re-evaluated Annually– Maintain a copy of these determinations
Hazardous Waste:The Nuts and Bolts
■ Large & Small Quantity Generator Status– LQG < accumulate HW for 90 days SQG < accumulate HW for 180 days
■ Labeling– All drums of HW must be properly labeled:
» CENTRAL ACCUMULATION AREA– Label must have accumulation start date
» SATELLITE ACCUMULATION AREA– Label should NOT be dated until drum is full– Only 1 drum per waste stream can be located in an area
■ Management– Keep drums closed at all times. Avoid the following:
» An open funnel is an open drum = penalty » An unlocked ring around a solids drum is an open drum = penalty
■ Disposal– Cradle to Grave
» Responsibility of proper disposal and recordkeeping is always on the GENERATOR, not the hauler
■ Universal Waste– Bulbs, Batteries, Ballasts, Thermostats, etc.
» Must be in a closed, labeled and dated container» Can accumulate for up to 1-Year
Hazardous Waste:The Nuts and Bolts
■ Good Condition■ Compatible with waste ■ Closed unless filling or dispensing■ Clear markings
– Content – Hazard Associated with the waste (waste oil = toxic)– Start Date Accumulation
Hazardous Waste:State Regulated
■ Very Small Quantity Generator of Waste Oil– Can accumulate 270 gallons indefinitely
■ Labeling– All drums of HW must be properly labeled:
» CENTRAL ACCUMULATION AREA– Label must have accumulation start date
» SATELLITE ACCUMULATION AREA– Label should NOT be dated until drum is full– Only 1 drum per waste stream can be located in an area
■ Management– Keep drums closed at all times.
» An open funnel is an open drum» An unlocked ring around a solids drum is an open drum
■ Disposal– Cradle to Grave
» Responsibility of proper disposal and recordkeeping is always on the GENERATOR, not the hauler
■ One Drip Rule– Saturated Rags and Wipes– One drop of oil from the rag = saturated rag = state regulated hazardous waste
Hazardous Waste:State Regulated
■ DEP policy #92-02-Waste Management Guidance for Industrial Wipers and Sorptive Materials Contaminated with Waste Oil
■ May be managed as a non-hazardous waste provided:– They do not contain free flowing oil (one drip rule)– They are used only for spills or leaks when collection of waste oil
is not practicable.
Hazardous Waste:The Manifest
■ If the hazardous waste shipment goes directly to a Massachusetts hazardous waste facility, the generator does not have to submit a copy to MassDEP. If the shipment goes directly to an out-of-state hazardous waste facility, the generator must submit a fully executed photocopy of Copy 3 to MassDEP within 30 days of receiving it from the designated facility. Send to:– MassDEP, Bureau of Waste Prevention
Attention: MANIFESTOne Winter Street, 7th FloorBoston, MA 02108
Planning for 2017
• Hazardous Waste Management = 100% compliance 100% of the time
• Weekly Inspections
• On-site accumulation limits (LQG=90 days; SQG=180 days)
• Submit copies of manifests for out-of-state shipments (30 days)
Top Five Things Regulators Look For
■ #1 Container Management– Label information, closed containers
■ #2 Generator Status– Monthly Generation limits and on-site accumulation time limits
■ #3 Manifests – Signed manifests received back from disposal facility
■ #4 Inspections– Documented inspections (time/date/full name)
■ #5 Central Accumulation Area– Line of demarcation, signage, emergency call list, fire
extinguisher
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Timothy K. Kucab, CHMMDouglas A. Stellato
Air Quality
Breakfast Seminar Series
■ Agenda– Broad Regulatory Updates– Planning for 2017– Emergency Generators– Noise and Siting– Top 5
Broad Regulatory Updates
■ Plan Approvals– 1 Ton Actual De Minimis Exemption Records– CO2 Plan Approval Threshold
■ Source Registration– Small Source Exemption– Amend Reporting Deadlines
■ Engines and Turbines– Consistency with RICE NESHAP/NSPS
■ Solvent Metal Degreasing– High Precision Component Exemption
■ VOC and NOx RACT– Update RACT requirements (e.g., emissions
limitations, monitoring, recordkeeping)
Planning for 2017
■ Reporting Season– Semi-Annual / Annual Compliance Reports (January)– NESHAP/MACT Annual Updates (January, March)– Source Registration Reports (March, site specific)– Greenhouse Gas Reporting (March/April)
» Changes to MassDEP Reporting– Risk Management Program (Varies)
So You Operate a Generator…
New
Old
Emergency
Non-Emergency
Area Source
Major Source of HAP
Installation Date Generator Use Facility HAP
Emissions
Types of Requirements
■ Emergency– Monitoring – Recordkeeping – Operating Limitations– Fuel Requirements– Emissions Limitations
■ Non-Emergency– Controls – Performance Tests – Reporting– Notifications
Emergency Engines Nuts and Bolts
■ Emergency engines may operate for 100 hr/yr for any combination of the following:
■ maintenance/testing;■ emergency demand response ■ 50 hr/yr of the 100 hr/yr allocation can be used for:
– non-emergency situations if no financial arrangement
Emission Dispersion
■ “Good Engineering Practices”– No Shanty Caps or Egg Beaters– Vertical exhaust
■ Stack Height – Requirements May Vary– 10 Feet Above Nearest Roofline– If the stack is lower than 1.5 times the building height or lower
than the height of a structure that is within 5L of the stack (5L being five times the lesser of the height or maximum projected width of the structure) – MODELING REQUIRED
■ Other states have additional requirements
State Requirements
■ Individual Permits■ General Permits■ Permit-by-Rule■ Certifications
Siting Considerations
Siting Considerations
■ Impacts from Project– Sound Levels– Visual Impacts
Generator Housing
Generator Exhaust
Residence less than 25 feet away
Noise Considerations
■ Noise Policies – Sound Levels– Pure Tones
■ Zoning Specific Noise Provisions
■ Sound Level Monitoring
– Pre-Construction– Post-Construction– Ambient
Top Five Things Regulators Look For
■ #1 Recordkeeping– Every Permit Condition
■ #2 Reporting– Don’t Miss Deadlines
■ #3 Inspections– Document Required Inspections
■ #4 Non-Delegated Regulations– Local / State / Federal
■ #5 General Duty– Facility Condition
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Bill Potochniak, P.E. Project Manager
Water & Wastewater
Agenda – Water & Wastewater
■ Review of regulatory updates■ Review of some regulatory considerations■ Planning for 2017■ What regulators are looking for■ Questions
Regulatory Updates
■ Stormwater (MS4)■ Legionella in Water Systems
Stormwater (MS4)
■ April 2016 – EPA adopted the new MS4 permit– Applies to local communities – Also applies to state-owned facilities
» Hospitals, colleges, universities
■ Effective July 1, 2017■ NOI Due September 29, 2017■ SW Management Plan Due July 1, 2018■ Challenges
– Need detailed site plans (GIS) – May require retrofit– Requires stormwater and outfall plan
Legionella in Water Systems
■ ASHRAE Standard (188)■ Establishes risk management requirements for building water
systems■ Not a regulation but a standard■ Finalized in 2015 ■ Challenges
– Look at hazardous areas (humidifiers, cooling towers) – Determine control locations– Monitoring– Record Keeping
■ ASHRAE also issued a guideline (referenced in 188) which provides useful information to help minimize legionella contamination
Regulatory Considerations
■ 314 CMR 12 – O&M & Pretreat. Standards■ 310 CMR 22.22 – Cross Connections■ 40 CFR 112– Oil Storage■ 257 CMR 2- Grading and Staffing of WW
Systems
Regulatory Considerations
■ 314 CMR 12 – O&M & Pretreat. Standards– Ensure O&M Plans contain the10 requirements– Ensure that treatment systems have been designed and
plans stamped by a PE– Ensure that treatment systems have been designed to meet
standards outlined– Review the federal categorical standards outlined in 40 CFR
Regulatory Considerations
■ 310 CMR 22.22 – Cross Connections– Ensure that backflow preventers are present on water lines
and are inspected twice a year– Have spare parts kits available
Regulatory Considerations
■ 40 CFR 112– Oil Storage– Storage of more than 1,320 gallons of oil aboveground– In containers 55 gallons or larger– Includes vegetable oils (kitchens)– Includes transformers (even if you don’t own them)– Annual training is required– Routine visual inspections– Updates every five years (or if major changes)
Regulatory Considerations
■ 257 CMR 2 – Grading & Staffing– Ensure that your system is Graded with the DEP
http://www.mass.gov/eea/docs/dep/water/approvals/year-thru-alpha/w/wtpgrade.pdf
– Grading is based on the unit operations and system complexity, if changes to system must re-grade
– Staffing plans must be updated when operators change
Planning for 2017
■ Develop capital improvement plans for wastewater upgrades
■ Review wastewater discharge permit renewal dates
■ Review how process changes can impact WW systems
Planning for 2017
■ SPCC Plan Review■ MS4 Gap Analysis■ Legionella
Things Regulators Look For
1. Wastewater permits– Adherence to definition of industrial wastewater– Discharges from industrial washers (sterilization equipment,
cage washers, bottle washers)– Nutrient levels and loads
2. Wastewater treatment systems– Up-to-date O&M manuals– Up-to-date staffing plans with licensed operators– Up-to-date process flow diagrams
3. SPCC plans– Outfalls and tributary areas are identified– Methods of isolating a release identified– Fill ports located and spill pathways provided
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Brian F. Day, Senior Environmental Scientist
Hazardous Building Materials
Agenda – Regulatory Updates
■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health
Hazardous Building Material Assessments
Prepare Specs & Report of Findings
Find ALL Regulated Building Materials
• PRIOR to Renovation or Demolition
Investigate For:
• Asbestos• Oil/Hazardous Materials • Lead Based Paint• PCBs in Building
Materials
HBMA Inspection Types
– AHERA (Management Plans / 3 Year Inspections)
– OSHA (Hazard Communication) – Renovation / Demolition (Needed to Obtain Permits)
– Property Transfers / Purchases Serving Both Public and Private Sectors
Regulatory Requirements
The Watch Dogs– MassDEP
» Most Visible» Growing Enforcement Group» Control Contractors Work Methods » Levy Violations / Fines» Regional Variations / Interpretations
– MassDOS» Govern Licensure for Contractors and Consultants» Conduct Field Inspections / Mostly in Schools
Regulatory Requirements
– Environmental Protection Agency (EPA)» Create Federal Regulations and Standards» State Agencies Enforce EPA Regulations
– OSHA» Worker Protection» Hazard Communication » Building Inspections / Labeling
Regulatory Requirements
– AHERA» Governed by EPA / MassDOS» Regulates Asbestos in Schools» Inspections / Abatement Projects
■ Regulations have seen only minor changes in last several years
Planning for a Building Renovation/Demo?
■ Is your Building Subject to an Inspection?– Generally any structure (regardless of building age) requires a
survey– Used to confirm or deny the presence of asbestos, OHM etc.– Virtually all building materials are suspect for asbestos until
sampled ■ You should plan for the following:
– Use licensed, experienced asbestos inspectors– Provide inspector with drawings, plans, renovation / demolition
scope, previous inspection records and unlimited access to all areas of your building
– Prepare abatement specifications – Inspection is needed to secure renovation / demolition permits
Top Five Reasons You Need An HBMA
#1 – IT IS REQUIRED BY LAW
Top Five Reasons You Need An HBMA
#2 – PROTECT THE ENVIRONMENT
Top Five Reasons You Need An HBMA
#3 – PROTECT YOUR EMPLOYEES
Top Five Reasons You Need An HBMA
#4 – CONTROL YOUR CONTRACTOR
#5 PROTECT YOUR POCKETBOOK!
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
David Horowitz, P.E., CSP - Project Manager
Alan Stratton, CSP - Project Manager
Safety & Health
Agenda – Regulatory Updates
■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health■ Auditing
Regulatory Updates – Safety & Health
■ Respirable Crystalline Silica
■ Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015
■ Recording and Reporting of Occupational Injuries and Illnesses regulations
Regulatory Updates – Safety & Health
■ Respirable Crystalline Silica– Issue Date: March 25, 2016 / Effective Date: June 23, 2016– Compliance Dates:
» Construction: June 23, 2017 / General Industry: June 23, 2018– Highlights:
» New P.E.L. of 50 µg / 8 hour shift(1/2 Prior Limit in General Industry / 5 times lower in Construction)
» New Action Level of 25 µg / 8 hour shift» Requires initial, in some cases follow-up, exposure monitoring» Requires engineering controls and work practices» Requires development of an Exposure Control Plan» Must consider designated list of controls
Regulatory Updates – Safety & Health
■ Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015
■ Translation: Higher OSHA Fines– Highlights:
» Serious $7,000 → $12,741 per violationOther Than Serious $7,000 → $12,741 per violation
» Failure to Abate $7,000 → $12,741 per day» Willful or repeat $70,000 → $124,709 per violation
» Effective August 1, 2016» First increase in over 25 years» Allows future increases by January 15 every year
Regulatory Updates – Safety & Health
■ Recording and Reporting of Occupational Injuries and Illnesses regulations– Highlights:
» Large Businesses (≥ 250 employees)– Electronically file OSHA 300/300A/301 forms with OSHA– Begins July 1, 2017
» Small (High Risk) Industries (20 – 249 employees)– By SIC Code (e.g., utilities, construction, manufacturing)– Electronically file OSHA 300A forms with OSHA– Begins July 1, 2017
» Injury / Illness data will be available to the public» Employers can not retaliate for injury reporting
– Automatic drug testing can be a form of retaliation» Electronic reporting is being challenged and may be modified
Planning for 2017– Safety & Health
■ Annual Safety & Health Requirements– Post OSHA 300A Log: Post from Feb 1 → through April 30– Initial Training:
» LoTo, Emergency Action Plan, HazCom, PPE, Hearing Protection…– Refresher Training:
» Annual: Hearing Protection, Respirators, Access to Medical Records…» 3-Year: Powered Industrial Trucks
– Mandatory Program Reviews:» Exposure Control Plan (BB Pathogens), Confined Space, LoTo….
– Annual Evaluations:» Audiograms, Respirator Fit Tests
– Process Changes:» Training, Program Updates, Hazard Reviews, PPE Assessments…
Top Five Things Regulators Look For
1. The common / obvious violations» OSHA Top 10 List» Visible - Low hanging fruit (Extension cords, No Written Programs, No Training...)
2. OSHA Exempt Facilities? Public Facilities?» Subject to Department of Labor Standards = Subject to OSHA standards
3. Federal / Local Emphasis Programs» Fall Protection, Fork Trucks, Amputations, Process Safety...
4. Employee Complaints & Injuries5. High Risk – High Injury Rate Facilities / Operations
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
Doug Stellato, Project Compliance Specialist
Compliance Tools – Chemical Inventories & Compliance Calendars
Agenda – Compliance Tools
■ Chemical Inventories■ Recordkeeping Databases■ Compliance Calendars
Compliance Tools – Chemical Inventories
■ Track materials stored & quantity used■ Used for multiple programs
– Tier II– Greenhouse Gas Reports– Source Registration– TURA reporting– TRI reporting– Chemical Control Laws
■ Accuracy is essential– Over-reporting– Under-reporting– Amended reports
Compliance Tools – Chemical Inventories
Materials ordered
Manufacturing
Products Manufactured
CAS #
CAS #
CAS #
Product Flow
CAS #
CAS #
CAS #
Information Needs
Receiving Dock
Shipping Dock
Compliance Tools – Recordkeeping
■ Track materials used and emissions■ Used for multiple programs
– Air Permit Reporting– Air Permit Recordkeeping– TURA/TRI applicability
■ Track all conditions of permit!– VOC/HAP concentration limits– VOC/HAP emissions– Annual reports
Compliance Tools – Recordkeeping
Compliance Tools – Recordkeeping
Compliance Tools – Recordkeeping
Compliance Tools – Recordkeeping
Compliance Tools – Calendars
■ Track “typical” and non-“typical” reporting deadlines
■ Track inspections or sampling– Hazardous waste– SPCC & SWPPP– Wastewater sampling
■ Track Employee Training– Hazardous waste– DOT– SPCC & SWPPP– Wastewater licenses
Compliance Tools –Calendars
Conclusions
■ Chemical inventory – key for material use, storage, and emission calculations– Establish systems at receiving dock– Use information for multiple regulatory programs– Regularly check and test data accuracy (3rd party)
■ Recordkeeping– Use data to generate compliance reports– Ability to export data for other uses and metrics tracking– Stay up to date on regulatory changes
■ Compliance Calendars– Use alerts and reminders– List applicable programs and frequency– List non-applicable programs with thresholds– Integrate inventory, recordkeeping and calendar
Questions
Breakfast Seminar Series
EH&S Regulatory Updates
September 20 Taunton MassSeptember 27 Framingham Mass
David P. Horowitz, P.E., CSP, Project Manager
Auditing
Agenda – Regulatory Updates
■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health■ Auditing
Reasons to Conduct an Audit
■ Manage risk■ Supply chain requirements■ Certification/Program requirements■ Employee turnover
Common Regulatory Visits
■ Department of Labor Standards – Public Works
■ Occupational Safety & Health Administration (OSHA) – Emphasis Programs
■ Environmental Protection Agency (EPA) – Risk Management Planning
Planning for 2017– Auditing
■ Internal Auditing– Checklists– In house– Outsourced
Planning for 2017– Auditing
■ Self Audit Policy – EPA
» eDisclosure– MassDEP– Timelines to disclose– Timelines to correct findings– Some relief from penalties
Department of Labor Standards
■ Common Audit findings at Public Works Facilities:
– Lock out/Tag out– Respiratory Protection Plan– Written PPE Certification
OSHA
■ Common Audit Findings at Industrial Facilities– 7 of 10 are general
industry– 3 of 10 are
construction
EPA
■ Common Audit Findings at Industrial Facilities– Risk Management Planning
» Process Safety Information (PSI)
» Signage» Management of Change
(MOC) issues» Employee Training
Questions
Recommended