Hazardous Waste


Emergency Vehicle.pngI recently became aware of a journal (Fire Engineering) that has a variety of articles about fire, hazmat and safety. One the articles that came to my attention was by Steven M. De Lisi.   Mr. De Lisi retired after a fire service career spanning 27 years that included serving as a regional training manager for the Virginia Department of Fire Programs (VDFP) and most recently as the deputy chief for the Virginia Air Guard Fire Rescue.

His article, Hazmat Survival Tips: 10 Common Errors Committed During Incidents  addresses issues First Responders have dealing with a hazardous incident.  Today many companies have HazWoper trained personnel, many who might also find some interesting information within this article.  Hazardous incidents are becoming more common as more and more hazardous materials are being transported throughout the United States.  Companies need to make sure they are in compliance with both the US DOT (49 CFR parts 100-185) and OSHA (29CFR part 120).

 

 Hazmat Train Car

Trains transporting the most toxic hazardous materials must use the safest, most secure route.   Railroads will be required to route every train carrying the most toxic and dangerous hazardous materials on the safest and most secure route under a new federal rule announced today by U.S. Secretary of Transportation Mary E. Peters.

Railroads will be required to route every train carrying the most toxic and dangerous hazardous materials on the safest and most secure route under a new federal rule announced today by U.S. Secretary of Transportation Mary E. Peters.

“This strong measure better ensures that rail shipments of hazardous materials will reach their final destinations safely and without incident,” said Secretary Peters, noting the rule applies to trains hauling Poison Inhalation Hazard ( PIH ) commodities such as chlorine and anhydrous ammonia which are heavily used in farming, water purification, and manufacturing.

Secretary Peters explained that beginning June 1, the rule requires railroads to conduct a comprehensive safety and security risk analysis of its primary route and any practicable alternative routes over which it has authority to operate. The analysis must consider information provided by local communities and a minimum of 27 risk factors like trip length, volume and type of hazmat being moved, existing safety measures along the route, and population density, she said. Railroads must implement their routing decisions based on these analyses by September 2009.

In addition, the rule includes several rail security provisions designed to guard against tampering with the rail hazmat car during transportation, the Secretary said.

The new rule complements the Department’s proposal last month to increase by 500 percent on average the amount of energy a rail hazmat tank car must absorb during a train accident before a catastrophic failure occurs, Secretary Peters said. This dramatic improvement in puncture resistance can be achieved with innovative designs, materials, and technologies available today and in combination with speed restrictions, she said.

“Stronger hazmat tank cars moving on the safest and most secure rail routes will enhance safety for people living in big cities and rural towns all across America,” Secretary Peters said.

The interim final rule on rail hazmat routing was developed by the Department’s Pipeline and Hazardous Materials Safety Administration in consultation with the Federal Railroad Administration, and fully complies with the provisions of the Implementing Recommendations of the 9/11 Commission Act of 2007.
 

The US department of labor estimates that 5.6 million workers risk exposure to bloodborne pathogens, including human immunodeficiency virus (HIV), hepatitis B virus (HBV), and hepatitis C virus (HCV), while on the job. An OSHA Standard Bloodborne Pathogens (1910.1030) Training Program is essential for any person who may be “reasonably anticipated” to face contact with blood and other potentially infectious materials as the result of performing their job duties. Professions at risk include, but are not limited to, healthcare professionals, educators, cosmetologists, tattoo artists, and construction workers. Industries whose employees have contracted infection from bloodborne pathogens while on the job run the risk of an OSHA citation up to $70,000 for facilities not in full compliance with bloodborne pathogens standard.

The Occupational Safety and Health Administration (OSHA) has recently begun to strictly enforce the bloodborne pathogens standard. Facilities not in full compliance with the standard, including failure to provide proof of OSHA standard bloodborne pathogens training to all employees, have received up to 70,000 dollars in fines.

A Bloodborne Pathogen program should include, but not be limited to:

  • Exposure Control
  • Methods of Compliance
  • Personal Protective Equipment
  • Housekeeping
  • Regulated Waste Control
  • Communication of Hazards to Employees
  • Recordkeeping

It is the employers’ responsibility to train and inform their employees about hazards in the workplace.  It is also the responsibility of the employer to pay for all PPE necessary to keep the employee safe.

The Compliance Resource Center provides training and polices and procedures for Bloodborne Pathogens Programs and other OSHA and DOT compliance.

Discarded TVsHave you ever wondered about what’s inside that box you watch all the time?  Over 40 millions people have at least 1 TV which contain some or all of the hazardous materials listed below.  Many poeple are buying the new LCD or Plasma screen TVs. Hence, the old TV sets are being dicarded into landfills.  The Balitmore Sun recently reported how this could lead to seroius environmental problems. Environmental groups are very concerned about these hazardous materials going into the landfills and our soils.

TV sets and computer monitors are safe when they’re viewed under normal conditions in homes and offices. But when owners discard them, toxic materials inside can leak into the environment if the sets are not properly recycled. Here’s what’s inside:

Lead: Sets with cathode ray tubes (CRTs) contain 4 to 8 pounds. Used in screens and soldered circuit boards. Can cause brain damage, blood disorders, kidney damage and birth defects. Children are particularly vulnerable.

Mercury: Used in lamps of flat-screen liquid crystal displays (LCDs). High levels can contribute to brain and kidney damage, birth defects.

Cadmium: Used in phosphor coating of CRT screens. A carcinogen that accumulates in the body and can cause kidney damage.

Barium: Used inside CRTs. Short-term exposure can cause neurological problems and damage to heart, liver and spleen.

BFRs: Brominated flame retardants are used in wiring. Can disrupt hormones and immune system, especially in children.

PVC: Polyvinyl chloride insulates wires. Can emit toxic fumes when burned in incinerators and can leach out in landfills.

Electronics TakeBack Coalition, Consumer Electronics Association and the EPA are concerned about how this new waste stream will affect the amount of waste and the landfills in the upcoming years. 

What can we do?  Recycle your TV and/or computers properly.  Check with your recycling centers or the EPA to find the best way to keep these hazardous materials out of the landfills.  Be RESPONSIBLE!

Proposed revisions that will change the requirements for facilities subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are expected within weeks. According to EPA, the revisions will tailor and streamline requirements to particular industry sectors and facilities subject to the rule.

EPA Administrator Stephen L. Johnson recently signed a proposed rule to amend the rule at 40 CFR part 112.

All SPCC-regulated facilities would be potentially affected by the proposed amendments, through which EPA intends to provide:

Clarity on the general secondary containment requirements,
Flexibility in the security requirements,
Flexibility in the use of industry standards to comply with integrity testing requirements,
Additional flexibility in meeting the facility diagram requirements, and
Clarification on the flexibility provided by the definition of “facility.”
Some of the other proposed changes include exemptions and a definition of loading/unloading rack.

Plan template allowed for small facilities
The changes would also streamline requirements and allow the use of an SPCC Plan template for a subset of qualified facilities known as “Tier 1” qualified facilities (i.e., with no individual oil storage container with a capacity greater than 5,000 U.S. gallons up to an aggregate of 10,000 gallons).

Until then, comply with old rule
Nothing in this proposed rule removes any regulatory requirement for owners or operators of facilities in operation before Aug. 16, 2002, to develop, implement, and maintain an SPCC plan in accordance with the SPCC regulations then in effect. These facilities are required to maintain their plans until the applicable date for revising and implementing plans under the new amendments.

Public comments on the proposed changes will be accepted for 60 days following publication in the Federal Register, which is expected within two weeks. Information about the SPCC rule proposed amendments is available at www.epa.gov/oilspill/spcc_oct07.htm

It’s a beautiful fall day, crisp temperatures, leaves turning those beautiful shades of oranges, yellows and reds, and that touch of pumpkins in the air.  So what are safety managers thinking about?  They need to have all of this years training completed….soon.  They are going into the 4th quarter and need to have their budgets ready from next year.  They also need to make sure they have all of this years budget spent, so there is not too significant of a cut back for next year.

Here are some ideas that may help the process.  If you have not done all your training and have some money to spend, this is a great time to make sure it is complete.  OSHA, EPA, and DOT often first look at training records a when they come visiting. 

OSHA recommends and sometimes requires on-going training in a variety of areas. 
 ·  New employees and/or new polices and procedures require new training.
 ·  Changes in using or labeling of hazardous materials require training.
 ·  Making sure that people are re-certified in First Aid, CPR/AED. 
 ·  If you have HAZWOPER trained people, having an 8-hour refresher class.
 ·  Driver Safety Training.
 ·  Emergency Response Planning.

The US DOT requires Hazmat training if your organization ships hazardous materials by ground, air or ocean.  Employees involved in the shipping or receiving of hazardous materials MUST be trained every 3 years for ground transportation and every 2 years for air and/or ocean shipping.  Your employees require Hazmat training if your company manufacturers hazardous materials packaging,.  New employees must receive training within 90 days after employment. 
This training must include:
 1.  General Awareness Training
 2.  Function Specific Training
 3.  Safety Training
 4.  Security Awareness Training
 5.  In certain cases In-Depth Security Training

This site does not publish the fines that companies get when they are in violation of compliance.  However, a majority of these fines, lost work days, lost productivity and more, could have been avoided by spending money training the employees.

The Compliance Resource Center can do all this and more.  Whenever possible the training is customized to your organizations needs. 
HAVE A SAFE DAY!

 

Under The Big TopThe BIG show is almost here.   The National Safety Council’s Congress & Expo is scheduled for October 15, 16, & 17 in Chicago.  This is the largest Safety & Health expo in the world.  There will be about 140 educational sessions, 32 professional development seminars, and over 800 exhibitors.  Many companies send their safety teams to attend the educational seminars and then have their annual safety meeting afterwards.  It is also a great place to network and look for jobs.  My favorite part has always been the people I have met.  Safety and Health professionals from all over the world.  Click here for a link to the keynote speakers. 

If you have the opportunity, come and check it out, you won’t be sorry.

OSHA has issued a new directive, CPL 02-02-073–Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases. The directive updates policies and provides clarification to ensure uniform enforcement of the provisions in the Hazardous Waste Operations and Emergency Response standard that cover emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. It revises CPL 02-02-059, issued April 24, 1998.

Enforcement procedures for compliance officers who need to conduct inspections of emergency response operations are included in the revision. It defines additional terms and expands on training requirements for emergency responders and other groups such as skilled support personnel. New guidance is provided on how HAZWOPER may apply to unique events such as terrorist attacks and addresses OSHA’s role under the National Response Plan. OSHA says the update will assist other federal, state, and local personnel who have responsibilities under incident command systems and will assist in emergency response operations.

The instruction updates policy and provides clarification on the following issues:

  • HAZWOPER’s application to a terrorist incident response involving chemical, biological, radiological, or nuclear materials.
  • OSHA’s relationship with Homeland Security Presidential Directive (HSPD-5), including discussion addressing the National Response Plan (NRP), the Worker Safety and Health Support Annex, and the National Incident Management System (NIMS).
  • OSHA’s National Emergency Management Plan (NEMP) and Regional Emergency.
  • Management Plans (REMPs).
  • Definition of “First Receivers.”
  • OSHA’s “Best Practices for Hospital-Based First Receivers of Victims from Mass
  • Casualty Incidents Involving the Release of Hazardous Substances.”
  • Shelter-in-Place.
  • Damaged packages during shipping.
  • Skilled Support Personnel.
  • Emergency responder training levels.
  • Medical Surveillance for emergency responders.
  • Computer-based training.
  • Updates to citation guidelines.

 

IN an effort to help prevent injuries, illnesses and property damage, the American Society of Safety Engineers (ASSE) offers the following safety tips for businesses to use following a disaster. Although there is no one-size-fits-all program, these tips may help. First, businesses should do a hazard evaluation and assessment performed by a safety professional. Please note the following tips suggested to be done following a catastrophe such as a hurricane:

Structural Security: Have the structural integrity of the building or facility validated by qualified professionals before anyone enters the facility.

Safe Entry: Contact the proper government agencies to get approval to resume occupancy of the building. Do not enter a facility or building unless the proper clearances have been attained.

Cleanup Safety: Implement your cleanup and business resumption processes in a safe and healthful manner. You will accomplish nothing if your employees are injured or killed during the post-disaster phase-in period. Provide training in proper selection and use of personal protective equipment (PPE) for your employees and yourself such as eyewear, gloves and dust masks/respirators for cleaning, and where appropriate in other operations.

Air Quality Assessment: Make sure the atmosphere in the workplace environment is tested for asbestos and other chemical/toxic agents. Air quality is an issue businesses may wish to pay careful attention to when restarting business operations.

Ventilation: Have vents checked to assure that water heaters and gas furnaces are clear and operable. Dust and debris can stop or impede airflow decreasing its quality and healthfulness. Safely start up heating, ventilation and air conditioning (HVAC) systems, which include prior inspection of lines before energizing and pressurizing of the systems. Test your systems now after inspection or have a qualified specialist do so. Blow cold air through HVAC systems first, as opposed to warm air, as it will help prevent the growth of mold in duct systems.

Interior, Exterior Exposures: For interior spaces, ensure no wall or ceiling materials are in danger of falling. If such exposures do exist, the work environment is not ready for occupancy. Check for cracked windows and outside building materials, as these could fall onto pedestrians at any time — now and in the future.

Protection Equipment: For fire and smoke alarms it is important to assure that these have been cleaned and tested before allowing occupancy of the building. If such systems are wired into other systems, ensure that they are still compatible and work in an efficient and effective manner. Thorough inspection of firefighting systems such as sprinkler and chemical equipment functions is a must do item.

Electrical Safety: Have checks made of electrical systems, computer cables and telecommunications’ equipment to ensure that they are still safe and there is no danger of exposure to electricity. Wiring inspections should be conducted from the outside in to ensure all wiring and connections are not in danger of shorting out due to water damage from rain or fire-fighting efforts.

Use Existing Federal Guidelines: Utilize existing start-up guidance materials provided by government agencies such as the Federal Emergency Management Agency (FEMA), http://www.fema.gov, and NIOSH, http://www.cdc.gov/niosh.

Health/Sanitation Issues: The general facility sanitation systems with the facility should be inspected and tested to guard against potential employee exposure to toxic agents. Food sanitation should also be an issue. Any unused foodstuffs should be discarded. If the workspace has a kitchen, inspect oven hoods and other ventilation devices to ensure they are not clogged and are working efficiently.

Office Furniture: Inspect the furniture to ensure it can withstand expected loads and usages. Ensure that binder bins (storage devices screwed or bolted to railing systems on walls and panels) have not become unstable due to water damage or shaking due to explosions. Inspect office equipment to ensure it is level, stable, and cannot tip over.

Lighting: Make sure there are adequate illumination levels for employees. Emergency lighting should be checked to ensure it operates and functions in the correct manner.

Emergency Planning: Ensure that there is a clear path of egress for the emergency evacuation of employees, that the fire extinguishers are still operable and that checks for damage and serviceability are made to see if any fire extinguishers’ facilities were used during the disaster. If damage is found, they should be replaced immediately.

Solid/Hazardous Waste Removal: Broken glass, debris or other materials with cutting edges should be safely gathered and disposed immediately. Ensure that such materials can be disposed of before collection to avoid creating even bigger hazards for both employees and the public. Solid waste disposal will be an issue, especially if hazardous waste is involved. Evaluate waste disposal issues prior to beginning clean-up operations to ensure it can be properly disposed of. ASSE’s free “Hazardous Materials Safety Information Guide” has key info on this and is available by contacting customerservice@asse.org.

Power Checks: If there is no access to electricity on the site, do not use fueled generators or heaters indoors. Ensure that there are no gas and sewer leaks in your facility. You will need to check with your local utilities for information regarding power, gas, water, and sewer usage.

Check Mainframes: If your facility has mainframe computer applications, see that lines and cabling for chiller systems are checked to avoid chemical leak out.

Emergency Procedures: Create a new emergency plan and distribute it to employees as soon as they return to work. In case of emergency, designate a place for employees to gather once out of the building or a phone number they should call following the emergency so that all can be accounted for. Frequently update the emergency contact list of names and phone numbers.

Machine Inspections: Inspect the condition of drain, fill, plumbing and hydraulic lines on processes and machines. It would be prudent to have plumbing lines evaluated and tested in order to detect any hazardous gases.

Surfaces: Make sure flooring surfaces are acceptable and free from possible slips, trips and falls — the second leading cause of on-the-job deaths in the United States. ANSI standard A1264 - protection of floor and wall openings is a good starting point.

 

EGR.png Laptop.png

First Responders to Get WISER, Thanks to DOT, HHS
According to the U.S. Department of Transportation, the 2008 Emergency Response Guidebook is the go-to reference for first responders to help them quickly identify hazardous material classifications, determine the best response, and protect themselves and the public immediately after an incident. Now, because of a joint effort between DOT and the Department of Health and Human Services, responders will for the first time have electronic access to the guidebook’s info through laptops and PDAs for potentially even faster fact finding.

Signed in late June, an agreement between the DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) and the HHS National Library of Medicine led to the development of a special software application called the Wireless Information System for Emergency Responsers, or WISER, which makes the electronic guidebook accessible through palm devices like the Blackberry and other PDAs, some phones, and Windows-based laptops and desktops.

“This new digital tool will give our police, firefighters, and other emergency responders first on the scene the information they need to make the rapid-fire decisions necessary to protect the public and themselves,” said Ted Willke, PHMSA associate administrator for hazardous materials safety.

For more information, visit http://hazmat.dot.gov/pubs/erg/gydebook.htm/ . For information on WISER visit http://wiser.nlm.nih.gov/.

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