Page #: 1 of 7 Last Reviewed/Update Date: 4/28/11 Permitting and Licensing for Hazardous Material Use and Storage 1. Purpose / Background National Fire Protection Association (NFPA) codes, State of Massachusetts Regulations and the City of Cambridge govern the use and storage of hazardous materials. For purposes of this document, hazardous materials include flammable and combustible liquids, gasses, solids and oils. The City of Cambridge, requires permits for any quantity of material use or stored, while licenses are required (in addition to a permit) if threshold storage quantities/volumes are exceeded. 2. Scope This SOP outlines the permitting and licensing process for the use and storage of laboratory chemicals and compressed gases that are flammable, combustible or toxic in new and existing laboratories. The SOP also applies to the installation of fuel oil storage tanks and the subsequent storage of fuel oil for emergency generators or heating boilers installed during building renovations and/or new construction. 3. Prerequisites None 4. Procedures 4.1 Hazardous Material Use and Storage 4.1.1 Projects involving the construction of new laboratories New laboratories that will use and store hazardous materials (flammable/combustible liquids and compressed gases) to conduct research and/or coursework will require a permit issued by the Cambridge Fire Department (CFD.) To facilitate the permit application process, the responsible department laboratory or center (DLC) should develop a chemical inventory. The inventory shall be made available to the MIT Project Manager and the EHS Office within 60 days of CRSP approval of the project. 4.1.2 Hazardous Material Inventory The EHS office requires these inventories to be in (or compatible with) CHEMTRACKER the MIT inventory database tool or some other similar method (spreadsheet etc.) For labs which do not yet have inventory in a space, estimate the maximum inventory of materials that the lab will need to function effectively in the proposed space. Please note, that along with the owner, department, building and room; chemical information must include the chemical name, physical state (solid, liquid or gas), the volume or mass per container and the number of containers. CAS numbers are helpful for pure substances. 4.1.3 Requirements for permit and license applications The EHS Office is available to work with the project team to coordinate the application process and will prepare and submit an application for use and storage of hazardous material to CFD and/or license, as required. A letter or affidavit bearing a stamp from a registered architect or engineer may be required.
Page #: 2 of 7 Last Reviewed/Update Date: 4/28/11 The letter may be required by city officials as a means to document that the hazardous material storage amounts comply with the requirements of 780 CMR, Massachusetts Building Code sections 307 & 4D (see page 4.) If the construction and renovation project involves the installation of a fuel oil storage tank, then both an installation permit and an oil storage permit applications are required. Construction of a new building that includes underground parking will require a Garage and Gasoline Storage License application be completed and submitted to the City of Cambridge License Commission. 4.1.4 Laboratory renovations; Increasing flammable liquid and gas storage amounts The increase of flammable liquids and gasses stored in a building resulting from a laboratory renovation or new construction shall be evaluated by the project team and the EHS Office for compliance with applicable codes. If an increase in the amount of flammable materials stored in an existing building or renovated laboratory is planned, the DLC should contact the EHS Office for assistance. The EHS Office will work with the DLC and submit a revised application for flammable storage permit to CFD. 4.1.5 Oil Storage Tanks Oil storage tanks involving Consumptive Use exclusively for heating on the premises will not require registration, but does need a storage permit. When preparing to install a new tank, the Department of Facilities Project Manager should contact the EHS Office. The EHS Office maintains oil storage permit records and will determine if there is an existing permit or license on file for the building/proposed tank location. Existing permits may be revised, subject to approval by CFD. The MIT Spill Prevention Control and Countermeasure Plan (SPCC) must be updated to reflect new oil storage tanks/fuel storage, per EPA requirements. Quantities of fuel and new tank locations must be documented in the plan, as it is critical to spill prevention planning. The EHS Office will revise the MIT SPCC Plan after new tanks are installed. 4.1.6 Applying for a tank installation permit and/or license The MIT Project manager is responsible for ensuring that the contractor secures a tank installation permit from CFD. Application forms are available electronically at the following URL: http://www.mass.gov/dfs/osfm/forms/index.htm An annual oil storage permit is also required, prior to filling a new tank. This process is generally managed by the EHS Office. For new building construction, the General Contractor or MIT Project Manager may assume the responsibility for obtaining oil storage permits from CFD. Either party should contact the EHS Office for assistance. This oil storage permit application is available at the following URL: http://www.cambridgema.gov/cityofcambridge_content/documents/forms/annual_permit.pdf 4.1.7 Tank Installation Permit Form FP6 All oil storage tanks require a permit to install, using form FP6, issued by Cambridge Fire Department, Bureau of Fire Prevention, 491 Broadway, Cambridge MA 02138, telephone 617-349-4918, fax 617-349- 4912.
Page #: 3 of 7 Last Reviewed/Update Date: 4/28/11 The tank installation contractor must complete the Application for Permit, and submit it with an application fee payable to the City of Cambridge. Information required by the application form should be entered as follows: Name and address of tank owner: Massachusetts Institute of Technology EHS Office, Room N52-496, 77 Massachusetts Avenue, Cambridge, MA 02139 Name of Competent Operator: Leave blank By: (Signature of Applicant) Contact: Ed Ackerley @617-452-2312 or eakerley@mit.edu. The following information is generally required to be submitted as part of the installation permit application. A letter-affidavit may be required, that includes the following information: Type and size of tank UL listing of the tank What the tank will be used for Location of the tank Containment being provided (single or double-walled tank) Fire rating of the room the tank will be located in Location and type of piping to be used Containment being provided for the piping Pump and monitoring equipment being used Location of the fill/vent piping and containment being provided The Project Manager shall ensure that a copy of permit application is forwarded to the EHS office. After the tank has been installed, but prior to filling with oil, the project manager needs to notify the EHS Office. MIT will need to file an application for use and storage of fuel oil with the Cambridge Fire Department. This can be done by DOF or the EHS Office. 4.1.8 License Application- Form FP-2 If the capacity of the new tank causes the aggregate capacity of the building (by category) to exceed an existing licensed capacity or one of the thresholds below, then a State Fire Marshal License (Form FP-2) will also be required in addition to the FP-6 standard permit form. Limits by Class are shown below. For fuel oil, the key limit is 10,000 gallons. Exceeding the limits listed below triggers a requirement for a license: Class I liquids 793 (gallons*) Class I liquids 10,000 (gallons**) Class II liquids 10,000 (gallons) Class IIIA liquids 10,000 (gallons) Class IIIB liquids 10,000 (gallons) Flammable gases (within a building) 3000 (cubic feet)
Page #: 4 of 7 Last Reviewed/Update Date: 4/28/11 Flammable gases (outside a building 10,000 (cubic feet) Flammable solids 100 (pounds) * In containers of 60 gallons capacity or less, or in portable tanks over 60 gallons capacity. ** In storage tanks having a liquid capacity that exceeds 60 gallons capacity. The Project Manager and EHS Office will coordinate license applications, if necessary. In Cambridge, License applications must be filed with the Cambridge License Commission, 831 Massachusetts Avenue, Cambridge MA 02138. The license application process requires a public notice, a hearing, and an application fee that varies depending on site-specific circumstances. Information required by the license application form should be provided as follows: Location of land Cite MIT Building and Street Address (if applicable) Owner of land MIT, EHS Office, Room N52-496 or Owner s Name if not MIT. Address - 77 Massachusetts Avenue, Cambridge MA 02139 Owner s address if not MIT Occupancy/use of building - Enter academic, dormitory, or other, as appropriate Total capacity of tank Enter # in gallons Kind of fluid to be stored Enter fuel oil, diesel, kerosene etc. 4.1.9 Displaying permits and signage The Facilities EHS Manager is responsible for coordinating with the EHS Office and the Project Manager to ensure that copies of all permits are conspicuously posted on site, as required by the regulations, or that a sign is displayed that the permits are available elsewhere (e.g., in the EHS Office.) Entry doors to fuel storage rooms where tanks are located shall be posted with both NFPA diamonds, as well as signage indicating the tank size and fuel stored (e.g. Diesel Fuel, 1000 gallons.) 4.1.10 Tank Registration Form FP-290 New underground tanks may need to be registered with the State Fire Marshal using form FP 290. Note: tank registration requirements do not apply to above-ground tanks (AST.) The EHS office will prepare and submit form FP 290 to CFD. Once the Fire Department reviews and approves the submission, EHS will forward copies of the forms to the Massachusetts UST, Dept. of Fire Services, P.O. Box 1025, Stow, MA 01775 4.1.11 Renewal of annual storage/use permits and licenses The EHS Office will submit renewal applications for existing permits by November 30. Licenses are renewed by March 30.. Copies of renewed permits and licenses will be distributed to DOF (for fuel oil tanks) and the Parking Office (for parking garage licenses.) 5. Roles & Responsibilities The EHS Office is responsible for:
Page #: 5 of 7 Last Reviewed/Update Date: 4/28/11 Providing General Chemical Hygiene Training (web-based or classroom) and MIT Overview HAZCOM training that includes information on chemical hazards Maintaining up to date guidance pertaining to flammable liquids. Addressing questions or concerns pertaining to flammable liquids. Accompanying the Cambridge Fire Department on annual permit renewal inspections of use and storage areas for flammable liquids. Applying for flammable and combustible liquid and gas use and storage permits and licenses related to laboratory renovation or construction. Apply for and annual renewals for flammable and combustible liquid and gas storage licenses and permits. Maintain an inventory of hazardous material permits and licenses. PI s/supervisors are responsible for: Ensuring that those individuals that they supervise who work with flammable liquids receive adequate training. Ensuring that flammable liquids are used and stored safely and notifying the EHS Office of any anticipated changes in hazardous material use, types and quantities. Ensuring flammable liquids are used and stored in the smallest quantities necessary in the work areas that they supervise and that non-flammable, higher flash point, or less toxic materials are substituted for flammable liquids whenever possible. Ensuring appropriate PPE is available for work with flammable liquids. The DLC EHS Coordinator or Chemical Hygiene Officer is responsible for: Addressing questions or concerns regarding the use or storage of flammable liquids, and consulting with the EHS Office if necessary. Inspecting chemical storage areas during Level II inspections (twice/yr for laboratories, once/yr for facilities spaces) and notifying the appropriate personnel and/or the PI/Supervisor of issues found so that they can be corrected and prevented from re-occurring. Notifying the EHS Office of any anticipated changes in hazardous material use, types and quantities. The EHS Representatives are responsible for: Assisting the PI/Supervisors with the safe use and storage of flammable liquids in the work area. Specific duties may include periodically inspecting use and storage areas and keeping an inventory of flammable liquids. Notifying the EHS Coordinator of any anticipated changes in hazardous material use, types and quantities. Individuals using flammable liquids are responsible for: Knowing and following the storage rules for flammable liquids established in their laboratory/work area. Assuring that they have adequate training Using flammable liquids in accordance with training guidance provided, only in EHS Office certified, exhausted fume hoods. Reporting any incidents, problems or concerns with flammable liquids to their supervisor or the EHS Office. Wearing the PPE that is specified by their supervisor.
Page #: 6 of 7 Last Reviewed/Update Date: 4/28/11 Contractors using, storing, or dispensing flammable and combustible liquids on MIT property are responsible for: Ensuring that a fire protection program (per NFPA and Cambridge Fire Department requirements) has been developed and implemented during all phases of demolition and construction Ensuring that flammable and combustible liquids are used and stored in accordance with generally accepted safety practices, as well as regulatory requirements. Ensuring that MSDS s are available upon request Applying for and obtaining use and storage permits with CFD. The Department of Facilities is responsible for: Ensuring that tank installation and oil storage permits have been secured and posted. Ensuring that all tank installations meets applicable codes and that storage locations are equipped with secondary containment and are posted with NPFA diamonds. Notifying the EHS Office of any tank removals, installations or changes in the volume or location of drum quantities of hazardous materials. 6. Training None 7. Monitoring Requirements None 8. Record Management The EHS Office retains central files for all permits and license related to hazardous materials and fuel storage tanks. 9. References 9.1. Standards 780 CMR Massachusetts Building Code 527 CMR Massachusetts Fire Prevention Regulations 9.2. Other SOP/ SOG s MIT SOP Flammable and Combustible Liquids MIT SOP Compressed Gases 10. Definitions 10.1 Hazardous Material Any material that, because of its quantity, concentration, or physical or chemical characteristics, may pose a hazard to human health or the environment. General categories of hazardous materials include the following; Flammable and Combustible Materials Toxic Materials Corrosive Materials Oxidizers
Page #: 7 of 7 Last Reviewed/Update Date: 4/28/11 Compressed Gases Aerosols 10.2 Fuel oil Refined petroleum oil burned for energy, heating buildings or fueling back-up standby power generation. Typically stored in above-ground or below-ground fuel tanks. Common grades of fuel oil include #1, #2 (light oils/diesel) and #6 (heavy oil.) All are in use and stored at MIT. Fuel oils are combustible, designated an NFPA rating of 2. 10.3 Garage and Gasoline Storage License A registration document issued by the City if Cambridge License Commission. Holders of a license have received permission from the City of Cambridge to keep, store, manufacture flammables or Explosives at specific premises (location/property) in quantities greater than threshold amounts listed in the regulations. License requirements also apply to fuel oils, even though they are combustible. 10.4 Annual Fuel Permit (aka, use and storage permits) The Cambridge Fire Department issues permits subject to annual renewal. The permit allows for the use and storage of flammable materials, although the permit also applies to fuel oils, even though they are classified as combustible. 10.5 CAS Number CAS numbers are a widely accepted universal method for referencing chemical structures and substances. Chemical abstract service registry numbers are assigned to chemical substances and serve as a unique identifier.