Public Comment Period Open for General Permit (GP-14) for Crematories
The Pennsylvania Department of Environmental Protection (DEP) has proposed revisions to General Permit GP-14, which regulates human and animal crematory incinerators. A public comment period is open until March 24, 2025, giving crematory owners and operators a chance to voice their opinions on the proposed changes before they take effect.
Why This Matters to Crematory Operations
General Permit GP-14 is intended to provide a streamlined and cost-effective alternative to obtaining an individual State-Only Operating Permit for crematory operations. The proposed February 2025 updates introduce new requirements and clarifications that could impact compliance procedures, operating costs, and reporting obligations.
Key Changes from the August 2024 GP-14 to the Proposed February 2025 Version
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New Compliance Requirements for Units Charged When Cold
- If a crematory incinerator is charged before reaching 1600°F, the secondary chamber must now reach and hold 1600°F before the primary burner is fired and throughout the cremation cycle.
- Interlock systems must be configured to prevent primary chamber firing until the secondary chamber is at 1600°F.
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New Sulfur Content Recordkeeping for All Fuels
- Previously, only fuel oil sulfur content records were required. The new version expands this requirement to include natural gas, LP gas, and propane.
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Earlier Annual Reporting Deadline
- The deadline for submitting reports to DEP moves from March 1st to February 1st each year.
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Updated Electronic Submission Process
- Applications, renewals, and reporting must now be submitted through DEP’s new Public Upload with Electronic Payment system.
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Clarifications on Prohibited Materials
- Crematory operators must remove hazardous remedial devices (e.g., radioactive implants) “where feasible”, adding flexibility compared to the previous blanket prohibition.
How These Changes Could Affect Your Small Business
- More detailed compliance requirements for cold-start cremations may affect operating procedures.
- Additional fuel sulfur content tracking could create minor administrative issues or burdens.
- The earlier reporting deadline means adjusting compliance workflows to meet the new due date.
- Navigating DEP’s new electronic submission system may require familiarization with the updated process.
How to Submit Public Comments
- Deadline: March 24, 2025
- Submit Comments Online: https://www.ahs.dep.pa.gov/eComment/
Small crematory operations should review the proposed changes to the General Permit (GP-14) and provide feedback if deemed appropriate. Your input is important to ensuring that the GP-14 remains a practical and cost-effective option for small businesses while maintaining environmental compliance.
If you have questions or need assistance in understanding the proposed changes, please contact EMAP.