1. Thomas Balf, Nexus Environmental Partners, Policy Advisor to MBC & Susan Smits, Mabbett & Associates, Inc. Co-Chair, Safety, Environmental and Facilities Committee

2. What are the Environmental, Health and Safety Issues? Cambridge BiosafetyHazardous Material Storage Chemical Policy/Safer AlternativesNanotechnology DEP Toxics ReportingPharmaceuticals in Wastewater DPH Medical WastesPharmaceutical Waste Greenhouse GasesProcess Safety/Vessels Hazardous Wastes in LaboratoriesStormwater

3. We’ll Talk About: Trends and Themes (Tom) Two in Detail: (Susan) DEP Toxics DFS Process Safety

4. Mental stretch….& big picture look

5. #1 What used to be “Beyond Compliance” is the New Compliance Carbon management Green Building requirements Pollution Prevention/Chemicals

6. Where were these issues 5 years ago? FedStateLocalNGO Biosafety 3 & 4XX Chemical PolicyX DEP ToxicsXX DPH MedicalX GHG InventoryXX Haz Waste LabsXX Haz Mat StorageX NanotechXXX Pharma in WWXX Pharma WasteXX Process SafetyX StormwaterXXX

7. #2 Collaboration - Recent Positive Experience: DEP DPHs Cambridge Public Health Role of trade assocs Concerns… Follow through in time of limited resources Innocuous language that becomes lever for more… Language written for enforcement and inspectors

8. #3 Chemical Policy – not this year, but… California – moving ahead aggressively Green Screen: assessment tools being developed NGOs: EPA, Cleangredients, Clean Production Action

9. MassDEP Industrial Wastewater Toxics Discharge Reporting Purpose: identify/address significant environmental problems from the discharge of toxics to sewers e.g perchlorate case Mandatory toxics discharge reporting for 3,400 MA facilities including LQGs and random facilities 1900+ chemicals require reporting if discharged Facilities will receive a notification letter Web based reporting via eDEP Excel chemical inventory files can be partially uploaded/imported.

12. MassDEP Industrial Wastewater Toxics Discharge Reporting Potential Impacts to MBC Members Potentially significant reporting burden Possible need to perform chemical inventory and MSDS review Data may be publicly available Need for senior management official certification Need to register/use eDEP system

13. State Fire Marshall’s Office Process Safety Regulation Purpose: Minimize risk to public from harmful exposure due the unsafe processing of hazardous chemicals. Danvers Explosion

14. Draft 527 CMR 33 Hazardous Material Processing Developing Process Safety Reg. and permit program Categories based on amount processed e.g. vessel size 1 = <1.5 gallons 2 = 1.5 – 15 gallons 3 = 15 – 60 gallons 4 = > 60 gallons 5 = RMP or OSHA Process Safety Increasing regulatory burden for each category Annual permit from Fire Department for Cat. 2 – 5 All require emergency planning and post incident analysis Category 4 = limited process safety hazard eval 14Tom Balf tbalf@nexusep.comMBC

15. Draft 527 CMR 33 Hazardous Material Processing Exemptions include: NFPA Hazards if all < 2 - pH adjustment systems and water purification - Boilers, emergency generators, etc. - Collection of hazardous waste, SAAs, etc. Impacts to MBC Member Companies Increased regulatory burden Permit fees Fire Department inspections - Possible need for consultant 15Tom Balf tbalf@nexusep.comMBC