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?Cambridge Biosafety Hazardous Material Storage

Chemical Policy/Safer Alternatives

Nanotechnology

DEP Toxics Reporting Pharmaceuticals in Wastewater

DPH Medical Wastes Pharmaceutical Waste

Greenhouse Gases Process Safety/Vessels

Hazardous Wastes in Laboratories

Stormwater

We’ll Talk About:Trends and Themes (Tom)Two in Detail: (Susan)

DEP ToxicsDFS Process Safety

Mental stretch….& big picture look

#1 What used to be “Beyond Compliance” is the New ComplianceCarbon managementGreen Building requirementsPollution Prevention/Chemicals

Where were these issues 5 years ago?Fed State Local NGO

Biosafety 3 & 4

X X

Chemical Policy

X

DEP Toxics X X

DPH Medical X

GHG Inventory

X X

Haz Waste Labs

X X

Haz Mat Storage

X

Nanotech X X X

Pharma in WW

X X

Pharma Waste

X X

Process Safety

X

Stormwater X X X

#2 Collaboration - Recent Positive Experience:

DEPDPHsCambridge Public HealthRole of trade assocs

Concerns…Follow through in time of limited resourcesInnocuous language that becomes lever for

more…Language written for enforcement and inspectors

#3 Chemical Policy – not this year, but… California – moving ahead aggressivelyGreen Screen: assessment tools being developed

NGOs: EPA, Cleangredients, Clean Production Action

MassDEP Industrial Wastewater Toxics Discharge ReportingPurpose: 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 dischargedFacilities will receive a notification letterWeb based reporting via eDEPExcel chemical inventory files can be partially

uploaded/imported.

MassDEP Industrial Wastewater Toxics Discharge ReportingPotential Impacts to MBC Members

Potentially significant reporting burdenPossible need to perform chemical

inventory and MSDS reviewData may be publicly availableNeed for senior management official

certificationNeed to register/use eDEP system

State Fire Marshall’s Office Process Safety RegulationPurpose: Minimize risk to public from

harmful exposure due the unsafe processing of hazardous chemicals.

Danvers Explosion

Draft 527 CMR 33 Hazardous Material ProcessingDeveloping Process Safety Reg. and permit programCategories based on amount processed e.g. vessel

size1 = <1.5 gallons2 = 1.5 – 15 gallons3 = 15 – 60 gallons 4 = > 60 gallons5 = RMP or OSHA Process Safety

Increasing regulatory burden for each categoryAnnual permit from Fire Department for Cat. 2 – 5All require emergency planning and post incident

analysisCategory 4 = limited process safety hazard eval

14Tom Balf tbalf@nexusep.comMBC

Draft 527 CMR 33 Hazardous Material ProcessingExemptions 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 CompaniesIncreased regulatory burdenPermit feesFire Department inspections- Possible need for consultant

15Tom Balf tbalf@nexusep.comMBC