Hazardous Waste


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.

 

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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/.

Factory FireAccording to 29 CFR 1910.34, all workplaces in general industry except mobile workplaces such as vehicles or vessels must have a fire prevention plan. Your facility’s fire prevention plan must include, at a minimum, the following elements, as specified in 29CFR 1910.39(c):

  • A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard
  • Procedures to control accumulations of flammable and combustible waste materials
  • Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials
  • The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires
  • The name or job title of employees responsible for the control of fuel source hazards

In the past few years a few people have been asked this question,  “Should I train my employees to fight minor fires with a fire extinguisher?”  My answer is alwayS the same, train people as first responders to make sure they get everyone out of the building, use a fire extinguisher to help clear a path if needed.  Let trained fire fighters put your fire out.  OSHA has specific regulations for having and training a fire brigade

I have found that insurance companies which insure your building, would like to see employees to try and put out minor fires with a fire extinguisher.   In contrast the company who carries your health insurance wants to make sure everyone gets out of the building and let the trained fire fighters work on the fire.

Developing an Emergency Response Plan is an essential part of a company’s safety program and can save lives.  Develop a good one and PRACTICE IT OFTEN.

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Hazardous waste generators are required to maintain the following records in accordance with 40 CFR 262.40.

  • Completed manifests (a copy with handwritten signature of the owner/operator of the destination facility) for three years from the date the waste was accepted by the initial transporter.     

  • Biennial reports and exception reports for three years from the due date of the report (not applicable to small quantity generators, in accordance with 40 CFR 262.44).     

  • Records of any test results, waste analyses, or other determinations in accordance with 40 CFR 262.11 for three years from the date the waste was last sent for on-site or off-site treatment, storage, or disposal.

These periods of retention are automatically extended during the course of any unresolved enforcement action regarding the regulated activity or as requested by the EPA administrator or your state environmental agency. Moreover, other recordkeeping requirements are mandated by several other portions of the hazardous waste regulations. Conditionally exempt small quantity generators are not subject to these requirements, except as specified in 40 CFR 261.5(b).
 
 
The Compliance Resource Center offers customized 40-hour, 24-hour and 8-hour HazWoper training (29CFR part 120.00).  We can also design a site specific Emergency On-Site Response Plan.

Contact us at info@thecrcenter.com or 847-298-3063   

   

 

 


 
   

 

 

 

Hazmat Incident1.pngWorking with different companies, I am often asked about Hazmat plans.  How do I know if I need a plan, is a common question.  My answer is almost always the same, IF YOU HAVE MSDS SHEETS, YOU HAVE HAZARDOUS MATERIALS ON-SITE, and you need a plan according to OSHA 29CFR part 120.   So what do you need to do?  Here is a starting point:

  • Develop a statement of purpose.
  • What does the scope of your plan include?
  • Identifying whom within the organization has authority for the plan.
  • Contact local professionals (fire department hazmat commander) to help develop plan.
  • List all known hazards in the facilities covered by the plan, and their location(s) in your facility.
  • Describe appropriate emergency procedures, including a worker alert/evacuation system.
  • What is needed to outfit first responder?
  • How any incident is to be reported.
  • Necessary training for first responders, and all employees.
  • How and when to practice evaluation plan.
  • Revise your plan as new hazardous materials enter your facility.

If your local hazmat team response time could be delayed, your employees should have HazWoper training (Hazardous Waste Operations and Emergency Response).  Your first responders should have a minimum of 24-hours HazWoper training.  All employees should be trained on your emergency response plan. 

Be aware that many common materials are now classified as hazardous materials.  This link provided may give you some common hazardous materials you are not aware of.

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