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Electrical products and medical devices which are manufactured in the United States, and sold in the EU may be significantly impacted by recent updates to two sets of regulations:
As we discussed in the last edition of the SPEC Report, Massachusetts has enacted a new regulation (527 CMR 33) that requires a permit to process hazardous materials. While those in Category 4 should have completed their permit applications for the June 1stdeadline, the next deadline for Categories 3 and 2 is approaching at the end of year.
The recent incident in Texas has prompted us to think about understanding the risks associated with operating a facility handling hazardous materials, and how to prevent these types of incidents. (Current estimates reveal that the facility contained as much as 54,000 pounds of toxic anhydrous ammonia, and reported to the Texas State Health Services Department that it possessed 270 tons of ammonium nitrate.)
In several blog posts, we have discussed the importance of a variety of factors when purchasing or leasing industrial real estate. Previous posts focused on topics like code requirements and the appropriateness of the building for industrial use, such as multi-tenancy, zoning restrictions, etc. However, another significant factor in evaluating industrial real estate is the local community. The experience of a local company, while trying to relocate, highlights the challenges and pitfalls of heavy industry companies trying to relocate in facilities in a new community.
In February of last year, the Massachusetts Department of Fire Services enacted regulation 527 CMR 33 regarding the processing of hazardous material. This new regulation was developed in response to incidents of fire and explosion in Middleton in 2011, Danvers in 2006, and Leominster in 2005, all of which involved the processing of hazardous materials.
The new regulation means that any business which processes hazardous materials (in addition to storing them) will need a permit to continue to do so, beginning this year. It categorizes users into five categories with Category 5 (highest volumes) having the most requirements for permitting, while Category 1 (lowest volumes, vessel capacity less than or equal to 2.5 gallons) does not require a permit although users are still responsible for compliance. The permits must be renewed annually and are issued by the local fire department.