When was the last time you conducted a thorough review of the hazardous material processes occurring at your facility, in accordance with 527 CMR 60.8? This review should be conducted at least annually, and lab workers need to be reminded that they should keep EHS informed of changing processes.
If an initial assessment determined that all hazardous material processes fell into Category 1 due to being conducted in vessels less than two and a half gallons in capacity, no permit would be required with the local fire department. However, it is the responsibility of the company to keep an eye on the evolving processes, and document continuous review and assessment. If processes evolve to fall into one of the higher categories, a hazardous material process permit would need to be obtained from the local fire department. Remember to carefully consider the exemptions stipulated in the regulation when conducting the assessment.
When this regulation was first implemented, many companies spent a lot of time and energy conducting an evaluation of their processes. Remember to keep up those efforts and frequently evaluate the need for a hazardous material processing permit.