Environmental Health & Safety Compliance Blog

Why do I need to label my drums / stock materials / waste?

Posted by Rebecca McDaniel on Nov 4, 2009 12:48:00 PM

By Melissa Iozzo, Technical Specialist

“I know what’s in there!”, “it’s just water!”, “The transporter can label the stuff”.

Sound familiar? Take a walk around your lab or manufacturing floor. You run a tight ship; you have neatly filed folders filled with POs and receipts for materials going for use in all aspects of your business. You know who’s using what, where, when, how much, and at what point you are going to need to order more. So why do you have to label all this stuff!

I’ll tell you – because I don’t know what’s in them, and neither does the EPA, OSHA, the fire department, or any other agency that regularity audits facilities just like yours! It’s called hazard communication – and it’s at the top of the list when talking about safety.

Fines for unlabeled container run high across the board – and they sure can add up; especially if you are being audited by multiple facilities. Furthermore, the EPA and the fire department don’t discriminate – regardless of if you have water, piranha etch, oil, or hydrofluoric acid in that bottle on the sink. 100 mls of 2 gallons – if it’s not labeled, then you aren’t taking necessary measures to keep your employees, visitors, and contractors aware – and that is a safety violation.

Even scarier than fines is the safety of your people – you don’t want to be responsible for a spill, or even worse, an exposure in your facility when you don’t know what the chemical involved in was due to having new labels available! On top of that, if this stuff ends up out on the roads missing the proper labeling and markings, you get a whole new set of agencies and fines to deal with!

Luckily – though it may seem at a tedious task at first, labeling is quick, easy, and can sure save you a lot of time, money, and overall pain in the end – especially if you keep up with it. Triumvirate can help. We can profile your waste streams and stock materials and print out reusable labels for just about anything – so you have to do pretty much nothing!

Tags: EPA, Triumvirate Environmental, OSHA, Safety

A Cautionary Tale from the Annals of Emergency Spill Response

Posted by Mark Campanale on Oct 9, 2009 8:09:00 AM

Doug Graham

"Responders? We don't need no stinkin' responders!"

OK, here's the scenario: Our hypothetical employer- (factory, institution, research facility, hospital, take your pick) makes an executive decision to "out-source" all hazardous chemical emergency response actions to an outside contractor. All employees are instructed that in the case of a chemical spill, they are not to respond, but to call the internal emergency contact person, who will then call the outside spill response service provider. Hands off, nice and neat, no internal hazmat response team, no need for emergency spill response (HAZWOPER) training of employees, it's all good, right? . . . . . . . . right?

Not so fast. What this employer does not realize is that in the event of a release they are in fact:

1) deciding if the incident could threaten human health or the environment; ]

2) implementing an incident command system;

3) assigning roles and responsibilities;

4) implementing defensive and/or offensive response actions;

5) notifying, or failing to notify, outside agencies; and the list goes on!

This sure sounds like "responding", and a lot like the stuff that's covered in a good emergency response training class!

The question now becomes, are all the people involved in the response trained in accordance with their anticipated rolls and response actions? Also, have they the knowledge and tools to make the correct decisions and perform assigned tasks?

Crucial decisions are often made in the initial stages of a hazardous chemical release, often by employees not always thought of as "emergency responders". According to OSHA's emergency response training standard- 29 CFR 1910.120(q) (HAZWOPER), an employee must be trained to the level to which they are expected to respond- awareness level, operations level, or technician level.

A simple way to approach this is to think of employees as fitting into one of these three categories:

1. Those who may be first to discover a hazardous chemical release and are expected only to recognize a potential threat, run away, warn others in the area to do the same, and then call for help; or
2. those who may come back to take defensive actions at a safe distance; or
3. those who will put on a full chemical protective suit, atmosphere-supplying respirator, and perform reconnaissance or take offensive actions in areas that could be a threat.
Yup, those are the basic descriptions for the three levels of OSHA HAZWOPER training.

So, in conclusion, if we go back to our hypothetical employer, we see that hiring an outside spill contractor only serves to add a tool to the emergency coordinator's tool bag, just an additional role under the employer's incident command structure. They've neither transferred responsibility, reduced decision making, nor removed the need for employee training.


Tags: Training, OSHA, Hazardous Chemicals