See the latest EHS federal and state regulatory updates due to COVID-19

EHS Support for the Food & Beverage Industries

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FREE Webinar: Creating an Industrial Hygiene Sampling Plan

Apr 30, 2020 - 2:00 PM EDT

Regulatory Roundup

  • Refrigerant Management Update - EPA published a final rule on March 11, 2020 (40 CFR 82 Subpart F) that rescinds the November 18, 2016, extension of the leak repair provisions to appliances using non-exempt substitute refrigerants, such has hydrofluorocarbons. While food and beverage facilities may use ammonia for refrigeration, which has been and continues to be an exempt refrigerant under this rule, many facilities have large (≥50 lb) appliances containing either ozone-depleting substances (Class I or Class II) or substitutes.
  • Dust Control - The National Fire Protection Association recently issued a new standard that requires the preparation of a Dust Hazard Analysis by Sep 7, 2020 from many types of food manufacturers. Learn more>>
  • Sanitation Chemical Usage - Some states have regulations that can impact the amount and types of sanitizers and cleaners that can be used at food and beverage facilities. Affected facilities need worst case usage plans for these necessary sanitation chemicals to comply with state and local air quality regulations while ensuring food and worker safety. 

Client Comment

"Trinity recently helped us on some air permitting in Tennessee, Arkansas and Virginia. Across the board the knowledge, professionalism and engagement demonstrated has been exceptional! The combination of technical mastery, practicality and communication style put our staff at ease very quickly working with Trinity. On top of all of the technical capability these folks are just enjoyable to work with, or just to converse with."

Project Profiles

  • Dust Control at a Sugar Mill: To comply with NFPA's Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities (NFPA 61), a sugar processing mill selected Trinity to conduct a dust hazard analysis of affected industrial processes. The team applied a process hazard analysis approach in conjunction with guidance provided under various NFPA standards. We conducted a systematic review of portions of the mill to identify and evaluate potential fire, flash fire, and explosion hazards and prepared a report of the findings and recommendations to achieve the prevention and mitigation requirements of the standards. In addition, Trinity evaluated existing procedures and management system elements already in place at the mill that could be harnessed to comply with the Chapter 9 management system standards. As a result, the client was able to streamline the development of the combustible dust management program by leveraging existing program information required under the FDA's food safety standards. The client was also able to readily identify and address gaps identified in the DHA and conduct process improvements to reduce fire and explosion hazards.
  • Permitting for Expansion in Ontario: A pasta manufacturing facility in Toronto recently required Trinity's assistance with renewing its operating permit to allow for the expansion of the facility's production limits. Trinity was able to promptly respond and determined the facility would be eligible for registration with the Environmental Activity Sector Registry (EASR). Trinity was able to complete and register the facility with EASR within a month, allowing the facility to operate at higher production capacities while remaining compliant with the Ministry of the Environment, Conservation and Parks (MECP) requirements.
  • Regulatory Variance for Commercial Bakery: A major food manufacturer's Kansas bakery needed to replace its oxidizer, which would require the bakery ovens to be uncontrolled for two weeks during the installation. Trinity's team of local consultants and national industry experts prepared a variance document that allows the bakery to operate without the use of an oxidizer and avoiding the costly loss of production, critical during the current period of high demand. 
  • Multi-Media Support for California Pistachio Processor: Trinity was selected to provide multi-media support for a new pistachio processing facility in the San Joaquin Valley in central California. Trinity assisted with the project from conception to completion. We conducted the Phase I Environmental Site Assessment (ESA), obtained required land-use authorizations including a Conditional Use Permit (CUP), secured San Joaquin Valley Air Quality Management District (SJVAPCD) air quality permits, and prepared the Report of Waste Discharge (WDR) for land application of pistachio wastewater. We continue to provide ongoing compliance assistance with air quality and wastewater monitoring and reporting requirements, streamlining compliance efforts for efficient environmental management.
  • Reporting Support for Meat Packer: Meeting TRI Requirements: A new beef packing and by-product rendering facility in Idaho contacted regarding Toxics Release Inventory (TRI) applicability determination. Trinity completed a detailed TRI applicability determination and developed calculation spreadsheets that the facility could use for future TRI submittals. Due to the good quality work, the client asked for additional assistance with a Monitoring Plan to meet the requirements of the Greenhouse Gas (GHG) Mandatory Reporting Rule (MRR) and their first annual report under the GHG MRR. Trinity has also completed H2S monitoring for biogas produced in the facility's anaerobic digester to demonstrate compliance with their air permit.
  • Broad Environmental Support: Trinity has consultants in all geographic regions who are knowledgeable in food and beverage environmental issues. We have several major food and beverage companies with plants across the country in which Trinity provides a vast array of environmental services including TRI reporting, Tier II reporting, air permitting and compliance, SPCC, SWPPP, NPDES permitting and compliance, hazardous waste reporting, and industrial hygiene analysis.
  • Refrigerant Management Tracking: Trinity's refrigerant management team has assist multiple facilities with auditing records for compliance, developing internal procedures, preparing chronic leaker reports, and populating our Refrigerant Tracking Tool spreadsheet to maintain all required records for the facility. We help determine which appliances are covered by the regulation and which are now exempt from the leak repair provisions, keeping in mind that some of the rule requirements, including the sales restriction, technician certification requirements, reclamation standards, disposal standards, and requirements to use certified recovery equipment continue to apply to non-exempt substitutes.