January 1, 2014 was the deadline to file permit applications required by the Hazardous Material Process or Processing Regulation, 527 CMR 33.00. In order to determine if your facility is required to file a Category 2 or above permit application with the local fire department, assessments of the hazardous processes occurring at your facility should have been conducted and documented. There are numerous exemptions to this regulation which can make it tricky to determine if a process is covered or not. In addition, the vessel size is always the capacity of the vessel, not the actual volume contained in the vessel, which can further complicate an assessment. A very helpful FAQ can be found of the Department of Fire Services’ website. All of the factors involved in the determination of the category for each hazardous material process should be documented to clearly demonstrate how the assessment conclusion was drawn.
An integral part of conducting these assessments is to ensure that appropriate control measures are in place for each hazardous process. This presents the perfect opportunity to conduct job safety analyses, risk assessments, or lab audits to enhance your EHS program for 2014!
With many town flammable storage permits up for renewal, it is important to have documentation to show inspecting fire departments.