Avoid Common Compliance Mistakes Through Proper Chemical Management

Whether it is OSHA’s hazcom standard, one of EPA’s secondary containment regulations or the U.S. Department of Transportation’s (DOT) manifesting protocols, having processes in place to correctly identify, store and handle hazardous liquids will help you and your employer comply with regulations, improve safety, protect the environment and manage costs. In addition to potential fines for non-compliance with regulations, the cost of managing chemical safety, disposal and floor space ranges between $1 and $10 dollars for every $1 spent on chemicals, according to a survey conducted by the Chemical Strategy Partnership. That means that a facility that spends $20,000 on chemicals likely will spend anywhere from $20,000 to $200,000 to manage them. Proper management helps minimize these expenses.

Managing Chemical Inventories

Maintaining an accurate inventory of the chemicals used and stored onsite can be an onerous task, but is an essential first step toward compliance. Inventory and purchasing records may not tell the whole story – especially when purchasing is decentralized. In addition to reviewing any inventories that already may exist, it is important to routinely walk through each area of the facility to make sure that the list still reflects the chemicals that are onsite.

Assigning a specific individual the responsibility of maintaining chemical inventories and ensuring that the most recent information is being used for various plans can help facilities maintain an accurate inventory and encourage plan updates on a regular basis.

According to OSHA, a chemical inventory “should consist of all chemicals that are produced, imported or used by the company.” Without an accurate chemical inventory, collecting and maintaining safety data sheets (SDS), training and other elements of OSHA’s Hazard Communication Standard (29 CFR 1910.1200), companies likely are not in compliance.

Knowing a chemical’s hazards helps you comply with Resource Conservation and Recovery Act (RCRA) generator requirements, and knowing the quantities of chemicals in your facility also is important for other areas of EPA compliance. Spill prevention control and countermeasures (SPCC) plans are required for facilities that store more than 1,320 gallons of oil or oil products in aboveground storage containers. Emergency Planning and Community Right to Know (EPCRA) planning and reporting requirements for extremely hazardous substances are triggered at quantities as small as 1 lb. for some chemicals.

Proper management of chemicals also increases safety throughout the facility. Although no two facilities are the same, many have common areas that environmental and safety inspectors frequently check to gauge compliance.

Receiving Docks

It may not be as obvious, but some compliance elements of OSHA’s Powered Industrial Truck Standard (29 CFR 1910.178) hinge on knowing what chemicals are onsite. For example, the type of forklift and other powered industrial equipment used in a facility may be dependent on the chemicals used and stored there.

Forklifts and equipment require special designations if they will be used in locations where compressed gas cylinders, certain flammables and other types of hazardous chemicals are stored. The specific designations are determined by the types of hazards a chemical may present.

Although it is not a required training element under the Powered Industrial Truck Standard, teaching lift operators to identify hazardous materials can be extremely beneficial. Operators who can recognize container hazard labels likely will be more aware of safety issues and manage containers properly. They also can be a resource for collecting SDS that may accompany packing slips and otherwise would be discarded.

Managing chemical inventories also helps with material storage logistics. Both EPA and OSHA require incompatible chemicals be segregated from each other. Having a process in place to identify incompatible chemicals at the loading dock can help ensure that they won’t inadvertently be stored together.

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Fluid Dispensing

Areas where chemicals are transferred are likely spots for leaks and drips. If left unchecked, these spills can contribute to slip-and-fall accidents, both in the immediate area as well as aisles and other areas where the spilled liquids may be tracked. Leaks and spills that are not properly cleaned up also can violate stormwater (40 CFR 122.26) and SPCC (40 CFR 112) standards if the spills enter floor drains that lead to navigable waterways.

Providing the right tools in fluid dispensing areas, such as bung wrenches, non-drip pumps or faucets and absorbents or wipers to clean up small spills can help keep these areas clean and help the facility comply with OSHA’s Sanitation Standard (29 CFR 1910.141).

Processing and Manufacturing Areas Chemical usage in assembly, processing and other manufacturing areas can present hazards to workers when those chemicals spray, drip or leak. Several OSHA standards require identification of potential hazards and require that appropriate personal protective equipment (PPE) be provided and worn to protect workers from hazards that cannot be prevented by engineering or other controls. Violations of PPE standards are common; last year, there were nearly 2,100 violations of OSHA’s respiratory standard.

Slips, trips and falls in the workplace are even more common, and cause over 221,000 incidents each year, according to the Bureau of Labor and Statistics. Keeping aisles and walking surfaces clean and dry aids in compliance with OSHA’s clean, dry floor standard (29 CFR 1910.22) and can be considered a Best Management Practice (BMP) under EPA’s stormwater requirements.

Storage Areas

Failing to label containers, storing incompatible wastes near each other or for longer than the allowable time limit are among the top RCRA waste management violations. Violations of closed container requirements also are common. Containers need to be kept closed when waste is not being added or removed (40 CFR 264.173). Easy-tolatch lids and drum covers help workers comply with this requirement.

Labeling waste containers is required, and helps workers segregate wastes. Under RCRA’s mixture rule, listed hazardous wastes that are mixed with non-hazardous wastes make the entire mixture hazardous, leading to higher disposal and compliance costs.

Providing secondary containment helps ensure that spills in waste storage areas don’t become more of a problem. Secondary containment devices, like pallets, dikes and berms, also can help with waste segregation. Federal containment regulations for indoor storage require secondary containment devices to be able to contain 10 percent of the total volume stored or 100 percent of the volume of the largest container, whichever is greater (40 CFR 264.175). Some states have additional volume requirements.

Utilizing satellite accumulation areas (40 CFR 262.34) also can help with waste management. Because the waste is being collected at or near its point of generation and is under the control of an operator, it often is easier to keep wastes segregated. It also makes it easier for workers to properly handle wastes, because they don’t have to immediately take them to a centralized collection area.

Properly labeling containers both in satellite accumulation areas and waste storage areas is required by EPA, and also helps with DOT manifesting regulations.

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Plans and Training

Satisfying OSHA, EPA and DOT requirements is easier when chemical inventories are kept up-to-date and employees are able to follow the processes that are in place to help ensure safety and environmental protection. But even the best plans will fail if employees are not properly trained to understand chemical hazards. Regulations vary regarding when and how often employees need to be trained, but most require the training to be documented.

The effects of improper chemical management can be devastating to workers who are injured and to employers who suffer from the loss of workers, property damage and fines. Although proper chemical management takes a large commitment of time, the benefits of safety, lower chemical management costs and regulatory compliance are worth the effort.

Karen Hamel is a technical specialist for New Pig Corp. in Tipton, Pa. She can be reached at (800) HOT-HOGS or by email at [email protected].