Assessing Compliance with the CMAS GACT at a Chemical Manufacturing Facility

Dixon Environmental has completed a preliminary assessment to understand the CMAS implications for a chemical manufacturer with multiple facilities. Specifically, we were evaluating compliance with the regulatory language in the final CMAS rule, which was published in the Federal Register on October 29, 2009 (74 FR 56008) and has a deadline for full compliance of October 29, 2012.

Our assessment began by touring the company’s facilities, reviewing its process flow diagrams, written assessment reports, analyzing its processes, and performing telephone interviews with key staff. Together, this approach allowed us to evaluate the preliminary delineation of CMPUs based upon “family of materials” classifications. It also allowed us to identify potential CPMUs requiring further controls, outline additional informational needs, and provide recommendations on next steps.

Based on our findings, we have developed an action plan that contains a number of solutions to achieve compliance. We have also identified a number of regulatory interpretations that we are working to clarify, if not receive some relief.

At present, the only challenge is the finality of the rule itself, which is currently under review by EPA and may potentially be re-evaluated. Although this could change some of our recommendations, there are clear benefits to performing this preliminary applicability review now.