First-Time Toxic Permit Without On-Site Storage
Project Overview
In this project, a new client approached Sutok to obtain a first-time Toxic Permit without on-site storage.
Our Approach
We conducted an in-depth discussion to precisely define the client’s activities involving hazardous substances to be included in the permit.
We compiled the relevant data from Safety Data Sheets (SDSs), completed the required forms together with the client, and represented the client before the Ministry of Environmental Protection (MoEP) through to permit issuance.
Throughout the project, we maintained close, proactive communication with the client and supported them in sourcing subcontractors for hazardous materials transportation and external-warehouse storage.
What a Non-Storage toxic permit Entails
Under a Hazardous Substances Permit without on-site storage, the business must contract with qualified subcontractors to transport hazardous materials and store them in an external warehouse until use or sale.
Engaging subcontractors for transport and storage does not relieve the toxic permit holder or the designated Responsible Officer of their legal responsibilities for the hazardous substances.
Ongoing Responsibilities of the Permit Holder and Responsible Officer
Verify that each subcontractor presents a valid Hazardous Substances Permit covering the relevant substances or hazard classes that the business seeks to include in its own toxic permit.
Maintain and present an emergency response procedure that:
Defines the company’s responsibilities for preventing hazardous materials incidents to the greatest extent possible, and
Provides details of the hazardous substances under the company’s control at the time of contracting with the supplier, as well as during any hazardous materials incident (if the company is notified in real time).
Keep accurate hazardous substances registers (poisons logbooks).
Conclusion
Within the scope of hazardous substance permitting, requirements vary according to the specific activities requested. For a first-time toxic permit, a thorough initial consultation enables clear scoping of needs and streamlines the application process.