Massachusetts’ own version of process safety management, 527 CMR 33, continues with first year implementation filing deadlines for manufacturing operations that “involves or produces a hazardous material”. Five (5) permit categories have been established with Category 5 users involving or processing the greatest quantity of hazardous materials and Category 1 the least (i.e. vessels equal to or less than 2.5 gallons). The Category 4 & 5 deadlines have already passed, but the deadline to file for Categories 2 & 3 is January 1, 2014.
At a minimum, manufacturers must demonstrate proper management of hazardous materials that may include flammable, toxic, explosive and otherhazardous substances as defined in the rule, and depending on the category, submit emergency response plans and conduct post-incident analysis. Compliance with this new rule is in addition to complying with current federal rules. Because this rule is in its first year of implementation, it is important to determine if your facility is subject to these new requirements. Contact SAK Environmental for a complementary determination-of-applicability @ 978-688-7804 x112.