Environmental Health & Safety Compliance Blog

Main Accumulation Area Compliance: Time for a Refresh?

Posted by Rebecca McDaniel on Dec 21, 2009 2:07:00 PM

By Alexa Kaubris, Chemist

With all the rules and regulations, things can get confusing when you have an entire room filled with chemicals. If you’re overwhelmed don’t worry you’re not alone. Here are some helpful hints and reminders when inspecting or reorganizing your MAA in Massachusetts. Don’t forget, not only are there a ton of rules but they change from state to state.

1. Every hazardous waste bottle in the MAA needs a label with a) the words “Hazardous Waste” b) the constituents of the container written in full (no abbreviations or chemical formulas) c) the hazards of the bottle identified (corrosive, ignitable, etc.) d) the date the container was filled in its respective satellite accumulation area (SAA) or the date accumulation began if you fill drums in the MAA.

Do: Make sure you can see this label.

Do: Make sure the container is closed tightly.

Do: Inspect the containers for leaks and cracks.

Do: Make sure the label is on the side of the containers (not on the top).

Hint: It’s always a good idea to label empty drums and containers in the MAA for clarity.

2. These bottles should be segregated out into secondary containment bins so that incompatible chemicals won’t react and an underlying impermeable surface will be ensured.

3. The room itself needs to have an impervious underlying surface, a base that slopes or elevated containers in case of a leak, and run-on needs to be prevented unless containment has excess capacity. Basically, if you have a spill, you need to make sure the other chemicals you are storing in the MAA won’t be sitting in the mess.

Do: Check expansion joints on concrete pads.

Do: Make sure there are no drains in the MAA.

Do: Make sure every hazardous waste container in the MAA is in a designated area for waste. Putting tape on the floor is a quick way to delineate the waste area. Everything else should be stored elsewhere in the MAA.

Hint: For best management practices any material labeled as non-hazardous should be kept separate for the hazardous material.

4. Watch out for aisle spacing! If the waste is not reactive or ignitable all you need is enough room to inspect each row. If the waste is ignitable or reactive you need four feet as required by the NFPA chapter 30.985(3).

Hint: If you’re tight on space, one solution is to make a double row of drums back to back in the middle of the room and then give 4ft to either side. Another is using a pallet to separate containers if you need to stack them.

Fast Facts: Reactives/Ignitables need to be stored 50 feet from the property line. The fire department does not like Reactives/Ignitables to be stored in underground rooms like basements (waste or not). The idea behind this being safety of personnel that would have to respond to a fire in a basement when there are limited entrance/exits.

Good luck and have fun! Be sure to take before and after pictures. Make-overs are the best!

Tags: Hazardous, MAA, Main Accumulation Area, Compliance

Compliance with the DOT HAZMAT Shipping Regulations

Posted by Rebecca McDaniel on Dec 2, 2009 7:33:00 AM

By Doug Graham, CHMM

The DOT hazardous materials regulations are a lengthy, complex set of rules with wide-sweeping applicability in many facilities. Investigating all the employees, vendors, materials, and shipment types involving hazmats can be challenging. To make matters worse, shipments may be originating from numerous departments, not necessarily immediately obvious to EH&S staff. Here are a few examples, I’ve heard many times over the years- “I didn’t know the lab was shipping dry ice by air”, “the engineering department has their own FedEx account?”, “Materials Management sent back hazardous chemicals to the supplier in a regular box?”, and my personal favorite- “who authorized him to sign hazardous waste manifests?”.

Here are 10 steps one can take to get a handle on DOT hazardous materials compliance-

1. Identify all potentially-regulated hazardous materials (hazardous wastes, medical /biological wastes, biological products and specimens, dry ice, radioactive materials, and hazardous chemicals (e.g., poisons, corrosives, gases, oxidizers, and flammables) that could potentially be shipped from each department.

2. Identify the modes of transport and carriers and the regulations applicable to each (e.g., 49 CFR for ground and UPS domestic air; IATA for FedEx Express; IMDG for international marine).

3. Identify all employees who have responsibilities related to preparing hazardous materials for transport (“hazmat employees”).

4. Develop training program(s) for those employees addressing general awareness, function-specific, and security issues, including training specific to 49 CFR, IATA, and IMDG, when applicable.

5. Train new hazmat employees within 90 days and retrain every 36 months.

6. Create shipping procedures for regularly-offered hazardous materials, and an auditing system to check shipments prepared by contractors, such as hazardous waste profiles, manifests, and labels prepared by waste vendors.

7. Keep up to date by reviewing regulatory changes on a yearly basis (49 CFR effective each Oct. 1, IATA effective each Jan. 1).

8. Maintain records and administrative programs, including annual registration, security planning, training records, past shipping papers, incident reports, and current regulations.

9. Know when and where to ask for help, e.g., Hazmat hotline, consultants.

10. Self-audit on a regular basis, be prepared for a regulatory or corporate audit, and reinforce through training, review and accountability.

Tags: Hazardous, Hazardous Materials, EHS, DOT, IATA, 49 CFR, Hazardous Chemicals

Staying in compliance while cutting cost

Posted by Rebecca McDaniel on Nov 17, 2009 7:39:00 AM

By Joseph Shupp, Chemist II

The economic slump that the economy is currently in has forced industries, especially smaller scale companies, to evaluate where they are financially and where they need to be to stay in business. Our industry of hazardous waste management and disposal is heavily driven by meeting regulatory standards. One of the many regulations that we all must follow is having the proper training that we need to do our jobs. Not only must we attend training and receive a certificate, but we also must re-certify on a pre-determined time frame. These trainings are rarely located in our backyard and have numerous cost associated with attending the training. Flights, meals, and hotel rooms are an overhead cost that is tough to cover when your company is cutting budgets and evaluating every penny that is spent.

The solution is to bring the desired training topics to your office. Web seminars and web based training modules are becoming an increasing popular item among companies who need to stay up to date with training regiments, but cannot necessarily afford to send all of there employees to external training centers. These web based programs meet all required regulatory aspects. Some of the trainings include videos and interactive modules to utilize a more hands on approach. In some cases the programs are broken up into sections which allow the trainee to work at there own pace. Upon completion of the modules a test will most likely follow. Once the test is passed a certificate can either be printed directly from the web page or an official certificate is mailed to the person testing. After it is all finished the two basic goals where achieved; training requirements are satisfied, and money has been saved.

Tags: Hazardous, Hazardous Waste Disposal, Training, DOT Training, Hazardous Waste Management