Massachusetts Office of Technical Assistance Advisory: Preventive Hazard Evaluation for Process Safety
The 2012 Massachusetts Fire Code hazardous material processing regulation (527 CMR 33) requires a hazard evaluation or limited process safety program for many companies that have never faced this requirement before, (though many companies have been essentially performing these tasks as good practice).1 Many companies covered by this regulation must now document that a hazard evaluation has been done, and safety measures are being integrated into operations. Preparing for emergencies involving hazardous chemicals processing requires an understanding of what can go wrong and how to control it if it does. Preventing such emergencies requires an understanding of alternative ways of accomplishing work without creating the hazards that pose a risk of harm. OSHA’s Process Safety Management (PSM) and EPA’s Risk Management Program (RMP) rules set standards for large facilities posing risks of significant property damage or toxic releases to the community. The new Fire Code regulation provides facilities with lesser risks (Categories 3 and 4) the flexibility to formulate an approach that is appropriate for the facility. This advisory concerns the essentials of preventive hazard evaluation, and the formalization of the process in a way that fits the scale of operations and which captures the potential value of the effort. All facilities that have processes that pose risks should implement preventive hazard evaluation to reduce the chance of an accident involving injury or other losses.
The Office of Technical Assistance and Technology (OTA) prepared and completed in May 2013 A Report on Barriers to Reducing the Use of Asthma-Related Chemicals. The report compares what we know about the use of three asthma-related chemicals, (chlorine, formaldehyde, and isocyanates), showing how the lack of information about use and chemical use reduction options is a barrier to reducing use outside of TURA. (The use of these chemicals by companies covered by TURA has significantly reduced over time). The report contains recommendations to the Toxics Use Reduction (TUR) Administrative Council on actions that might help reduce the use of asthma-related chemicals, an important strategy for the prevention of this disease, which is rising in Massachusetts.
- The Massachusetts Office of Technical Assistance (OTA) is responsible for helping entities in the state achieve superior environmental, health and safety performance while also improving economic sustainability. Nanotechnology is a very promising set of industries. It creates a wide range of opportunity for innovation in areas such as biomedical devices, improved electronic devices, clean energy technology, and materials engineering . There is vast potential for environmental improvement, along with the economic benefits of new products of higher quality and greater variety. At the same time, there are indications of potential harm from certain exposures and releases of engineered nanoparticles (ENPs), and it is essential to recognize, reduce and control these risks when they are present. An effective program for reducing or eliminating potential risks would be premised on adequate recognition of where those risks might arise, and a continuous effort to apply preventive strategies. This guidance document is provided for the express purpose of assisting in the development of this technology, as failure to prevent exposures or releases will not just risk harm to health or the environment - it will also impede the common interest in realizing the benefits that nanotechnology can provide.
- The Office of Technical Assistance and Technology (OTA) developed this Environmental Guidance document to continue assistance efforts to the Medical Device sector and to reduce environmental barriers and liabilities that might hinder the sector. The Guide is a roadmap tailored to meet the unique needs of medical device manufacturers in Massachusetts. This guide is designed to:¿ Identify and compile DfE and Pollution Prevention concepts, resources and tools¿ Identify relevant environmental requirements and issues, and provide access to the corresponding environmental regulations¿ Offer compliance assistance and guidance¿ Provide case studies and examples
- Changes in state and federal reporting requirements have increased the importance of lead use reduction by manufacturers in Massachusetts, particularly those in the electronics industry. In 1999, EPA classified lead and lead compounds as Persistent, Bioaccumulative, and Toxic (PBT) chemicals. PBT chemicals are a concern because they are highly toxic, do not break down easily in the environment, and accumulate in living tissues. Because of these three characteristics, the TRI/TURA reporting thresholds for lead have been reduced from 25,000 pounds per year processed to only 100 pounds per year which means that if your facility uses 270 pounds or more of 63Sn/37Pb solder per year, you trip the threshold. This change is part of a nationwide initiative to reduce the risks to human health and the environment from exposure to PBT pollutants.
- The Marine Science and Technology (MS&T) industry is an important cluster of the Commonwealth of Massachusetts and a diverse industry that includes: instrumentation, services, research, shipbuilding, materials and supplies. To help the industry realize its potential contribution to economic development in Massachusetts, the Executive Office of Environmental Affairs (EOEA) Office of Technical Assistance and Technology (OTA) launched a study of the potential environmental barriers that might impede the growth of the industry in Massachusetts. The Issues Paper developed as a part of this study suggested that the MS&T industry faces a number of barriers to growth. Challenges facing this sector include uneven participation in current environmental regulatory programs and new domestic and international restrictions on products containing toxic materials such as lead. In effort to examine and verify these conclusions, a focus group meeting of representatives from the MS&T community was held and a final report with the findings of this meeting are now available to download. For additional information, please contact Jim Cain at 617-626-1081.
The Economic & Operational Impact of Environmental Regulations and New International Standards On Your Business: A Focus Group Meeting For the Marine Science & Technology IndustryThe Marine Science and Technology (MS&T) industry is an important cluster of the Commonwealth of Massachusetts and a diverse industry that includes: instrumentation, services, research, shipbuilding, materials and supplies. To help the industry realize its potential contribution to economic development in Massachusetts, the Executive Office of Environmental Affairs (EOEA) Office of Technical Assistance and Technology (OTA) launched a study of the potential environmental barriers that might impede the growth of the industry in Massachusetts. The Issues Paper developed as a part of this study suggested that the MS&T industry faces a number of barriers to growth. Challenges facing this sector include uneven participation in current environmental regulatory programs and new domestic and international restrictions on products containing toxic materials such as lead. In effort to examine and verify these conclusions, a focus group meeting of representatives from the MS&T community was held and a final report with the findings of this meeting are now available to download. For additional information, please contact Jim Cain at 617-626-1081.
- The wire & cable-related sector of the plastics industry is important to the economy of Massachusetts, representing 1.6 billion dollars in sales, according to an industry source, and employing 1700. Eliminating lead and other toxics from the compounding of formulations used, without affecting product quality, is a significant human health and environmental achievement. When cable manufacturers change their formulations (compounds or colorants) to eliminate lead or other materials of concern, the testing and approval process is similar to that required for most formulation changes. The purpose of this fact sheet is to review strategies for streamlining the testing and certification process - such streamlining can reduce time to market and costs.
Barriers to Eliminating Chlorinated Solvent Use In Cleaning Operations At Massachusetts ManufacturersSAK Environmental, LLC (SAK) was retained by the Massachusetts Executive Office of Environmental Affairs, Office of Technical Assistance (OTA). The primary purpose of this project was to identify barriers to reducing or eliminating chlorinated solvent use for manufacturing companies in Massachusetts.
- The medical device industry is important to the future growth and economic development of the Commonwealth. To support this growth and to reduce potential environmental barriers and liabilities impeding the growth of the sector, the Massachusetts Office of Technical Assistance for Toxics Use Reduction (OTA) held a focus group meeting with the manufacturers of the following three types of medical devices in Massachusetts - surgical and medical instruments; electromedical and electrotherapeutic apparatuses; and surgical appliances and supplies. The meeting was held June 24, 2004 at Nypro's corporate facilities in Clinton, Massachusetts. A report that details the findings of the meeting is available to download. If you have any questions about the report please contact John Raschko at 617-626-1093.
- OTA hosted a meeting titled: The Business Case for Design for the Environment for Medical Device Manufacturers, which was co-sponsored by MassMEDIC, Associated Industries of Massachusetts, Greater Boston Chamber of Commerce, Executive Office of Environmental Affairs and the Office of Technical Assistance. This half-day workshop was convened by EOEA to assist business leaders and product development team members to understand emerging environmental issues, identify key risks and opportunities, and learn about leading corporate practices in the medical device sector. The final report is available to download. . If you have any questions about the report please contact John Raschko at 617-626-1093.
- The EMS Guide provides a clear, concise, step-by-step introduction to the environmental management system framework. It also includes recommendations and example contract language to help facilities contract an appropriate facilitator.
- A comprehensive, plain-language manual designed to help the auto body repair industry in Massachusetts: understand and comply with the environmental, health and safety requirements, and learn about and implement various pollution prevention strategies and other best management practices.
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