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The Regulatory Environment in Massachusetts: Today…and…tomorrow

The Regulatory Environment in Massachusetts: Today…and…tomorrow. Thomas Balf, Nexus Environmental Partners, Policy Advisor to MBC & Susan Smits, Mabbett & Associates, Inc. Co-Chair , Safety, Environmental and Facilities Committee . What are the Environmental, Health and Safety Issues?.

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The Regulatory Environment in Massachusetts: Today…and…tomorrow

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  1. The Regulatory Environment in Massachusetts: Today…and…tomorrow Thomas Balf, Nexus Environmental Partners, Policy Advisor to MBC & Susan Smits, Mabbett & Associates, Inc. Co-Chair , Safety, Environmental and Facilities Committee

  2. What are the Environmental, Health and Safety Issues?

  3. We’ll Talk About: • Trends and Themes (Tom) • Two in Detail: (Susan) • DEP Toxics • DFS Process Safety

  4. Mental stretch….& big picture look

  5. #1 What used to be “Beyond Compliance” is the New Compliance • Carbon management • Green Building requirements • Pollution Prevention/Chemicals

  6. Where were these issues 5 years ago?

  7. #2 Collaboration - • Recent Positive Experience: • DEP • DPHs • Cambridge Public Health • Role of trade assocs • Concerns… • Follow through in time of limited resources • Innocuous language that becomes lever for more… • Language written for enforcement and inspectors

  8. #3 Chemical Policy – not this year, but… • California – moving ahead aggressively • Green Screen: assessment tools being developed • NGOs: EPA, Cleangredients, Clean Production Action

  9. MassDEP Industrial Wastewater Toxics Discharge Reporting • Purpose: identify/address significant environmental problems from the discharge of toxics to sewers e.g perchlorate case • Mandatory toxics discharge reporting for 3,400 MA facilities including LQGs and random facilities • 1900+ chemicals require reporting if discharged • Facilities will receive a notification letter • Web based reporting via eDEP • Excel chemical inventory files can be partially uploaded/imported.

  10. MassDEP Industrial Wastewater Toxics Discharge Reporting Potential Impacts to MBC Members • Potentially significant reporting burden • Possible need to perform chemical inventory and MSDS review • Data may be publicly available • Need for senior management official certification • Need to register/use eDEP system

  11. State Fire Marshall’s Office Process Safety Regulation Purpose: Minimize risk to public from harmful exposure due the unsafe processing of hazardous chemicals. Danvers Explosion

  12. Draft 527 CMR 33 Hazardous Material Processing • Developing Process Safety Reg. and permit program • Categories based on amount processed e.g. vessel size • 1 = <1.5 gallons • 2 = 1.5 – 15 gallons • 3 = 15 – 60 gallons • 4 = > 60 gallons • 5 = RMP or OSHA Process Safety • Increasing regulatory burden for each category • Annual permit from Fire Department for Cat. 2 – 5 • All require emergency planning and post incident analysis • Category 4 = limited process safety hazard eval MBC Tom Balf tbalf@nexusep.com 14

  13. Draft 527 CMR 33 Hazardous Material Processing • Exemptions include: • NFPA Hazards if all < 2 • pH adjustment systems and water purification • Boilers, emergency generators, etc. • Collection of hazardous waste, SAAs, etc. • Impacts to MBC Member Companies • Increased regulatory burden • Permit fees • Fire Department inspections • Possible need for consultant MBC Tom Balf tbalf@nexusep.com 15

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