Deadline nearing for Hazardous Material Process or Processing (527 CMR 33) permit applications

The new year is fast approaching, and so is the deadline to submit permit applications for 527 CMR 33 – Hazardous Material Process or Processing. On or before January 1, 2014, companies that fall under Categories 2 and 3 are required to submit their permit applications.

As a refresher, Category 2 companies have a process which involves or produces a hazardous material which occurs in a vessel that is greater than 2.5 gallons but less than or equal to 60 gallons. Companies that fall under this category must have the following in place in addition to submitting the permit application by the deadline:

• Hazard Communication Program • Chemical Hygiene Program • Flammable Storage Permit/License • Emergency Response Planning

Category 3 companies have a process which involves or produces a hazardous material which occurs in a vessel greater than 60 gallons but less than or equal to 300 gallons, or a process that is conducted in an area that is classified as an H-occupancy per the Massachusetts Building Code. Companies that fall under this category must fulfill all the same requirements as Category 2, but must also have in place a:

• Process Hazard Evaluation for each Category 3 process • Procedure for Post Incident Analysis

CAPACCIO has successfully helped companies come into compliance with this regulation and has worked with local fire departments to obtain the necessary permits. It is important that you are prepared to educate the fire department about your processes and that you involve them early in the process. If your permit is denied, the fire department may require an evaluation by a third party.

With the deadline drawing near, CAPACCIO can ensure that all the necessary leg work is done and the last minute details are taken care of before submitting your permit application to the fire department. We can help with determining your applicability and process category, updating your plans and policies, implementing applicable program requirements, compiling and preparing specific documentation to demonstrate compliance to the regulation, preparing your permit, and working with your local fire department to submit your permit.

Please contact Christopher Walton, PE, BCEE, Senior Associate, at 508.970.0033 ext. 139 or if you require assistance on some or all of these tasks to ensure you meet the January 1 deadline.

#527CMR33compliance #527CMR33permitting #HazardousMaterialProcessorProcessing

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