arrangements with local authorities

Arrangements with Local Authorities: Example Letter

EXAMPLE

 (Insert Company Letterhead)

 

 

Date

 

Name of Local Police Department / Fire Department / Other Emergency Response Team / Emergency Response Contractors or Suppliers / Local Hospitals / (if applicable) Local Emergency Planning Committee

Attn: Local Authority Contact

Street Address

City, State, Zip code

 

Dear Local Authority Contact:

This letter is written as a requirement of the Hazardous Waste Rules adopted by the State of Your State.  The purpose of this letter is to document arrangements to familiarize (Name of Local Authority) with the layout of the facility; types, quantities, and properties of hazardous waste handled at the facility and associated hazards; places where facility personnel would normally be working; entrances to roads inside the facility; possible evacuation routes; and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility.

Name of Facility is located at Address of Facility. Name of the Facility engages in activities that make it subject to the preparedness, prevention, and emergency procedures of USEPA and Your State; these include:

  • Include a description of the activities/processes that occur at the site.

Hazardous waste is generated as a result of describe the process generating hazardous waste, and is accumulated at this facility. In accordance with select which applies: 40 CFR 262.16(b)(8)(vi) [for SQGs] or 40 CFR 262.256 [for LQGs], we are providing your facility with the following information:

  • A layout of the facility showing areas where hazardous waste is generated and accumulated, places where facility personnel would normally be working, entrances to roads inside the facility and possible evacuation routes. (Attach information)
  • A description of the types, quantities, and properties of hazardous waste handled at the facility and the associated hazards. (Attach information or describe here)
  • A description of the types of injuries or illnesses which could result from fires, explosions, or releases at the facility. (Attach information or describe here).

We are requesting that your facility provide the following services in the event of an emergency regarding hazardous waste generation and accumulation at the facility:

  • (Describe/Specify the requested Services) (Where more than one police or fire department might respond, facility must have agreements designating primary emergency authority to a specific police or fire department, and agreements with any others to provide support to the primary emergency authority)

If you do not agree with the arrangements, have questions, or need additional information please call me at Phone Number of Facility.

Sincerely,

 

Facility Contact Signature

Facility Contact Name

 

The Requirements of 40 CFR 265.37 Arrangements with Local Authorities for Hazardous Waste Generators

In the previous article of this series I described the requirements of 40 CFR 265.35 – Required aisle space.  That section of Part 265 indicated what was needed to provide the necessary aisle space within a facility.  Though §265.36 exists, it is reserved, so there are no regulations to review currently.

The purpose of this article: identify and explain the requirements of 40 CFR 265.37 – Arrangements with local authorities for generators of hazardous waste under the emergency preparedness and prevention regulations of 40 CFR 265, subpart C.  This article is the seventh – and last – in a series that looked closely at each section of 40 CFR 265, Subpart C and explained its requirements, how they apply to generators of hazardous waste, and what is required for compliance.  Keep in mind that the regulations of your State may differ from these Federal regulations.

Hold on a minute!  These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule.  If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer).  If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you.  Read: What is the status of the Generator Improvements Rule in my state?

To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:

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To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article. (more…)