Massachusetts is currently rolling out new regulations: 527 CMR 33.00, Hazardous Materials Process and Processing. This action stems from several serious industrial incidents involving chemicals, such as the Danvers explosion, in which improper management of chemicals lead to a serious incident. It requires companies that process hazardous materials (e.g., mixing, purifying, heating, cooling, compressing, pressurizing, distilling, blending, or chemical reaction process such as oxidation or polymerization) conduct a process hazard analysis of their equipment, handling procedures and safeguards, evaluate risk, and then apply to their local fire department for a permit for each vessel involved. For companies with process vessels of less than or equal to 300 gallons in volume (i.e., Category 2 & 3), this requirement becomes effective January 1, 2014; companies with larger vessels have already had to comply. Wastewater treatment is exempt.

If you manufacture, and use chemicals, now is the time to review these regulations, impacts to your company, your current dispensing and handling procedures, safety and operating procedures, staff training and schedules, emergency equipment, and relationships with local emergency response officials. Get your applications in before the deadline! If you have questions or need help, GEC has EHS professionals to assist.

GEC attended an awards presentation at the State House in Boston in which ChemGenes Corporation, a GEC client for many years, received an award from the Massachusetts Department of Environmental Protection Commissioner Kenneth Kimmell for achievements in Toxic Use Reduction. GEC partnered with ChemGenes in 2005, and has helped by working with ChemGenes' staff to develop practical Toxic Use Reduction Plans, evaluating options, technology and process improvements, and also helping with implementation. As a result, ChemGenes selected and implemented feasible toxic solvent reduction options including reformulation and substitution, that required requalification of products made with modified solvent blends, and also process and equipment improvements. In addition, since their manufacturing processes traditionally use large amounts of high purity solvent for product purification, GEC suggested that ChemGenes consider applying for a TURI grant, which they did, and were awarded a financial incentive grant to assist their efforts at implementing solvent recycling on-site. This financial boost enabled ChemGenes identify capable equipment manufacturers, run qualifying trials, and then purchase and install fractional distillation equipment to begin processing their own spent solvent on-site, enabling them to reuse recovered solvent in future batches. Every gallon of solvent processed yields a high percentage of recovered reusable solvent, saving ChemGenes the cost of purchasing new solvent, and reducing waste disposal costs associated with the former one-pass solvent process; a win-win formula.

GEC attended a meeting where an EPA representative relayed his experiences inspecting, purging, and inspecting, purging and organizing chemicals stored in science labs within schools throughout Massachusetts. His team, consisting of trained interns, found cabinets overstocked with unneeded chemicals, mercury thermometers, and numerous hazards. The team collected, assembled and inventoried all containers of chemicals, and mercury thermometers. Chemicals were evaluated for container condition, hazard class, volume on hand, curriculum needs as compared to normal high school science and chemistry requirements and then either entered into a database, returned to inventory, organized, or staged for disposal. Unnecessary chemicals were lab-packed off-site, at the school's expense, and properly disposed. A chemical inventory database was created that will serve as a useful tool for future chemical purchases, waste disposal, issuing chemicals, accountability, and tracking usage of all chemicals. The chemical team also measured and checked laboratory fume hood exhaust performance, and safety showers and eyewashes, often finding inoperable or inaccessible equipment. In the end, schools ended up with safer labs, educated faculty and staff, an in-house champion to carry-on after the EPA team was gone, and tools and equipment for improved chemical safety and control. Their motto: "Do No Harm to Our Children." Their offer to help schools in need is still open to anyone who cares to partner with them. Seems like a pretty good deal! Contact GEC for details.