EHS permitting and licensing in compliance with Federal, State, and Local regulations is a crucial item to address for all companies.
Many cities and towns have local ordinances that establish requirements for recombinant DNA permits and hazardous material storage permits. Wastewater discharge typically needs to be permitted through the regulatory agency having jurisdiction, which is commonly the Massachusetts Water Resources Authority in eastern Massachusetts. Any facility generating hazardous waste must be appropriately registered as a Very Small Quantity Generator, Small Quantity Generator, or Large Quantity Generator. The use of radioactive material requires a license from the MA Department of Public Health Radiation Control Program. From the basic permits and licenses that most companies need to the specific import/export permits or DOT registration, it is critical that your company holds the appropriate permits and licenses.
Many permit/license applications require detailed information that is not always easily accessible, and supporting documentation that needs to be developed. The paperwork associated with the applications takes time to complete, and then there are often long lead times for regulatory agencies to issue permits and licenses after receiving the application. It is not uncommon for a permit or license to take up 60-90 days to receive, so this lead time needs to be factored into planning.
Once the necessary permits and licenses are obtained, compliance with the associated regulations and specific conditions of the permit or license must be maintained. Almost all permits and licenses have expiration dates, so renewal applications must be filed in sufficient time for a new permit or license to be issued before the existing one expires. There may be specific conditions established in the permit or license, such as recordkeeping or reporting criteria, which makes it crucial to read every permit and license issued to your facility upon receipt.
Be prepared for an unannounced regulatory inspection by having all the necessary permits and licenses, and an organized and compliant program.