Guide To Managing And Minimizing Hazardous Wastes In The Shop
The scenario: Jim, a new technician, attempted to move a full drum of used oil from one area in the shop to another using a hand truck. The drum was strapped onto the equipment, but moving the oil caused the contents inside to slosh, unbalancing the load and causing Jim to lose control. The whole contraption tipped over and used oil began spilling out of an open bung hole in the top of the drum.
Jim looked around, but couldn’t see any way to keep the spilled oil from reaching a drain only a few feet away. The floor sloped toward the drain, and the oil quickly reached it.
Jim worked as quickly as he could to right the drum, but several gallons of oil were released before he got things under control. Finally, one of his coworkers noticed what had happened and pointed to the spill kit in the corner. Jim used a few sorbent pillows and some sawdust to stop the oil spill from spreading. “Now what?” Jim wondered.
We’ll come back to Jim and his situation in a bit, but first, ask yourself if this sort of thing could happen in your shop. If you have used oil or hazardous waste at your facility, you need to plan now to avoid your worst-case scenario.
The rules that apply to all generators of hazardous waste require planning for responding to releases. Larger generators must develop formal plans called contingency plans, but smaller generators have to plan for emergencies, too.
Whether or not you need to come up with an official contingency plan or an informal plan, you must minimize the risk of fires, explosions or other accidents at your facility.
Know the Regulations that Affect You
The U.S. EPA and the states require you to identify all of your waste streams and determine whether they are hazardous. Most waste produced by businesses are solid wastes, meaning they can be sent to a state-approved or municipal solid waste disposal facility.
But some solid wastes are also hazardous wastes, and are highly regulated at the federal and state level.
Typical wastes in a shop setting include:
- Used oil
- Used oil filters
- Solvents
- Aerosol cans
- Brake pads
- Antifreeze
- All of the rags, absorbents and other materials used to apply and clean up these materials
Keeping the volume of these wastes down, managing them to meet other regulatory programs or switching to less hazardous products can help to keep you a “small generator.”
The less hazardous waste you generate, the less regulated you are.
Plan and Prepare for Emergencies
All generators must take steps to minimize the potential risks of the hazardous waste they store, including chemical reactions, fires, explosions, spills and other releases. Generators must follow progressively stricter regulations for their emergency preparations, depending on their size.
Of course, preparing for emergencies is a best practice for all facilities, and may be required by other regulatory programs such as Occupational Safety and Health Administration’s emergency action plans and fire prevention plans at 29 CFR 1910.28 and .39.
Make Arrangements with Local Emergency Responders
Unless you plan to equip and train your employees to respond to emergencies on their own, you’ll need to work with local emergency responders. Generators can train with community first responders to prepare for the types of emergencies that are most likely to occur at the facility.
Local authorities, such as the police department, fire department, ambulance service and local hospitals will want to know:
- The layout of the facility
- Properties of the hazardous waste and other hazardous substances handled at the facility
- Locations where employees normally work
- Entrances to roads inside the facility
- Possible evacuation routes
You should also make local hospitals aware of the hazards of the waste handled at your facility, along with the types of injuries that could be expected from fires, explosions or releases that occur.
Larger generators must document these arrangements.
Written Contingency Plans
Your contingency plan is where you describe the actions you will take to respond to emergencies. At a minimum, your plan must contain the following:
- A description of the actions employees will take in response to fires, explosions or other unplanned releases
- A description of the arrangements you’ve made with local emergency responders
- Names, addresses and phone numbers of anyone qualified to act as an emergency coordinator
- A list of all emergency equipment at your facility, including the location and physical description of each item on the list, and a brief description of its capabilities
- An employee evacuation plan, including the signal to evacuate, exit routes and alternate exit routes
Be sure to keep a copy of the plan at your facility and send a copy to local authorities.
Note that if you store used oil or other types of oil on your property in the amount of 1,320 gallons or more, then you are required to develop and maintain an oil-spill prevention plan under the EPA’s Spill Prevention, Control and Countermeasures (SPCC) rule. SPCC calls for more extensive measures than the hazardous waste contingency plans.
If you have an SPCC plan, EPA says you only need to amend that plan to also meet the contingency plan requirements.
Quick Reference Guide
A new requirement in the hazardous waste regulations is that facilities which have contingency plans must prepare a companion “quick reference guide.” The purpose of a quick reference guide is to help emergency personnel respond more efficiently to emergencies.
Quick reference guides should only contain the following information:
1. The type of waste managed at your facility. Use layman’s terms and include the hazards associated with the waste.
2. The amount of waste at your facility.
3. Any unique hazards of the waste that would require special treatment by medical staff for exposures to it.
4. A map of the facility with accumulation areas marked.
5. A street map showing the facility in relation to surrounding businesses, schools and residential areas.
6. The location of emergency equipment, such as fire hydrants and their flow rates.
7. The identification of on-site notification systems.
8. The name of the emergency coordinator and 24/7 emergency numbers.
Your Emergency Coordinator
You must appoint at least one emergency coordinator who will be responsible for putting your plan into action. This person will activate the alarm system, notify employees about the emergency and notify outside emergency responders.
The emergency coordinator must be capable of assessing the situation and notifying the surrounding neighborhood, state and local responders, and/or the National Response Center (NRC), if necessary.
Put your Plan into Action
If the worst does happen, and you have a fire, explosion or large spill of hazardous waste or used oil that threatens human health outside your facility, or there is a possibility of the spill reaching surface water, you’ll need to activate your contingency plan. This means notifying your emergency coordinator.
EPA provides the steps emergency coordinators must take for various hazardous waste emergencies:
For a fire: Call the fire department or attempt to extinguish the fire using a fire extinguisher. Note: Only trained personnel should attempt to put out a fire. If you instruct your employees to evacuate in the event of a fire, the coordinator should perform a head count at a prearranged location.
For a spill: Contain the spill as much as possible and clean up the waste as soon as possible to the greatest extent possible. Clean up any contaminated materials or soil.
For fires, explosions or releases that threaten human health or the environment outside the facility, or when the spill has reached surface water, immediately notify the NRC.
Required Notifications
You may need to activate the local emergency response system. This could include employees trained to respond to emergencies, along with the local fire department, first responders, hospitals and police. In addition, you or the emergency coordinator must:
1. Call the NRC at 800-424-8802. The NRC will evaluate your situation and help you make appropriate emergency decisions.
If you are unsure if the situation warrants a call to the NRC, call. In many cases, you will find the problem was not a true emergency, but you’re better off calling. Failing to report emergencies within a very short timeframe carries serious penalties.
2. Notify your state emergency response commission, if required. Check your state’s chemical emergency website for directions.
Back to the Scenario
Getting back to Jim and his situation, we see that training this new employee on proper waste management and emergency preparedness could have prevented this spill from getting so out-of-hand.
First, using a hand truck to move a heavy drum of used oil may not have been the best choice. Perhaps a pallet jack or forklift should have been used.
Next, the drum’s bung hole should not have been left open. The regulations require containers of used oil, and hazardous waste, to be closed at all times, except when adding or removing waste. If the hole had been closed, oil could not have leaked out.
Once the spill occurred, Jim did not know what to do. Training on the emergency procedures, including how to sound the alarm and where to find the spill kit, could have helped him stop the spill sooner.
Finally, drains in the shop should always be covered to prevent oils, chemicals and contaminated wastewaters from reaching the storm sewer or groundwater. Once a waste escapes into the drain, you have a much bigger problem on your hands than a small oil spill in your facility.
Put it Together
It’s in your best interest to minimize the amount of hazardous waste and used oil you generate in the shop. Using less hazardous materials to begin with is usually the least expensive and most effective way to do this.
However, for the hazardous materials you still have on hand, you must develop a plan to prevent and prepare for emergencies. The more you plan, the better off you are.
Lisa Neuberger is the editor of “Workplace Safety” for J. J. Keller & Associates (www.jjkeller.com), a leading provider of regulatory, safety and compliance solutions. With subject-matter expertise spanning a multitude of industries and regulatory agencies, the company offers products and services that help organizations create safe work environments, and simplify the complexities of regulatory compliance. Neuberger specializes in workplace safety and environmental topics for industrial markets. She provides daily environmental news updates for customers and responds to questions concerning solid and hazardous wastes, safety committees, sanitation, OSHA injury and illness recordkeeping and other related topics, and has authored a number of whitepapers on environmental topics.
