Environmental Health and Safety Blog | EHSWire

By John Defillippo, CHMP

Do you have hazardous chemicals in your workplace? If you think the answer is no, are you sure?

OSHA defines a hazardous chemical as one that presents either a physical or a health hazard. Many common and readily available products such as paints, cleaners, and other materials found in the workplace meet this definition. In fact, last year OSHA issued over 6,300 violations to companies that failed to comply with this standard. As we noted in a previous blog, non-compliance with the Hazard Communication standard was the third-largest source of OSHA violations in 2009 and 2010!

If you are an employer, you have a legal obligation to provide a workplace that is free of recognized hazards and to communicate any hazards present to those in the workplace.  In 1985, OSHA established the Hazard Communication Standard ( 1910.1200) to ensure, in part, that all workers have the "right-to-know" about the hazardous chemicals in their workplace.

Essentially, employees have a Right-to-Know about any hazardous substances that they may come into contact with at work and how to protect themselves from adverse affects. Employees, for their part, have a responsibility to follow directions and work safely by using products for their intended purpose and in accordance with the manufacturer’s instructions to reduce risk and chance of exposure. This is where the Hazard Communication Standard “kicks in”, as all workplace information about hazardous substances needs to be in a Written Hazard Communication Program.  This "HazCom" program must contain

• A list of all hazardous chemicals in the workplace and a Material Safety Data Sheets (MSDS) for each chemical (or product) on that list


• All employees must have access to that list and the MSDS’s during their work shift


• Methods to communicate hazards of these chemicals to employees, on-site contractors and visitors such as signs and labels


• Records showing that all employees have been properly trained to understand the hazards, read the MSDSs and understand labeling and signs.

In addition to the federal OSHA requirements for labeling, the State of New Jersey has specific labeling requirements for all vessels, piping and containers that contain hazardous chemicals.

So, do you have hazardous chemicals in your workplace? Are you rethinking your answer?

If you have products that arrive with an MSDS, and you have not implemented a written HazCom Program, you’ll need to get a program in place to be OSHA compliant. If you have been following the standard, consider the following:

• Are you keeping up with its requirements?


• When was the last time your HazCom Program was reviewed?


• Is your hazardous chemical list and MSDS collection up-to-date?


• Do you know what OSHA considers “Hazardous”?


• Is every hazardous chemical container labeled properly – even the transfer containers?


• Are ALL your employees trained about the workings of your HazCom program and the hazards of each chemical in their workplace?

Now do you know the answer? Or, do you have more questions?

If you are confused or intimidated, don’t worry.  A great resource is the Institute of Hazardous Materials Managers which certifies individuals as Hazardous Materials Managers (CHMM) and Hazardous Materials Practitioners (CHMP). These trained professionals must demonstrate various levels of knowledge, expertise, and excellence in the management of hazardous materials. And, there are EHS (Environmental, Health and Safety) experts like Emilcott everywhere – their job is to help companies stay in compliance with state and federal regulations while protecting employees. No matter what resource you find, just ask if they are experienced in developing Hazardous Communication programs. Not only will workers stay health and safety, you’ll see added benefits like prevention of property damage, reduced insurance claims and costs, and, of course, your company will not be cited for OSHA’s third most-common violation!

Have you found any chemicals in your workplace that you didn’t know are hazardous? Does your “right-to-know” increase your job comfort level or concern you? And, have you carefully reviewed the company HazCom plan so that you understand “what to do if…”?

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, H&S Training, Hazardous Waste Management, HazCom, Compliance, regulation, General Industry, emergency response training, Exposure, hazardous chemicals, chemicals, MSDS, Hazard Communication Standard

By Don Hoeschele, MS, CHMM

In an age where we are reliant on modern technology as a part of our job, it is difficult to imagine not being able to use your cell phone or access the Internet because of topography.  As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”?  Specifically, I had to meet OSHA’s requirements for communication:  29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”.  

For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help?  In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it!

On this particular project, numerous construction crews were working at different, extremely remote locations with a distance of several miles between each work crew. While the power line tower construction and electric line-stringing companies included requirements for an eventual end-to-end 2-way radio system, the system was not available for at least the first year of the project. And, since cell phones and the average two-way radio systems were not able to be consistently or reliably available to meet the communication needs required for this project, I needed to find an alternative. 

After digging around and countless meetings, calls, and trips to all kinds of communications companies, we settled on a resourceful, cost-conscious and effective method of communicating between the crews, safety personnel, surveyors and managers. The end result was a creative mix of new technologies:

• Cell phone signal boosters in each vehicle in the field


• GPS SPOT locator units for each  crew


• New technology satellite phones for work crews heading into the most remote locations.  

The vendor that built these systems also owned many of the frequencies needed for an end-to-end two-way radio system that would reach across the 275-mile project location.

Of course, the system’s effectiveness had to be proven – we were relying on it! So, I spent hours deep in the mountains field testing the equipment in some of the most remote project locations I have ever seen. Luckily, I was helped by some of the project team members who had spent a great deal of time in this area. Experience also helps communication!

This project had unusual difficulties – a big, remote, mountainous and unpopulated area – that could have thwarted OSHA’s communication requirements.  At any time, it would have been easy to throw in the towel, cross our fingers or perhaps put together a patched-together system and hope it worked.  However, with some tenacious ingenuity and a confidence that a reliable health and safety communication system could be found, we were able to overcome the almost overwhelming challenges and put an effective field communication system into place.

Have you been faced with challenges to provide adequate communication systems for your employees?  What has made a job site seem almost impossible to conquer? What did you do to overcome those challenges?

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, HazCom, Compliance, worker safety, Occupational Health, Occupational Safety, Hazard Communication Standard, communication

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

Charles Peruffo

The Pollution Prevention Act (PPA) of 1990 (42 U.S.C. §13101 et seq. (1990)) was a paradigm shift in the control of pollution (and hazardous waste). While previous regulations emphasized the “end of the pipeline”, the PPA moved the control of pollution upstream in the manufacturing process to prevent the waste from being generated in the first place. Closely related to the PPA is the NJ Pollution Prevention Act.  Passed in 1991, the NJ PPA implements the concept of reduction in waste production “upstream” by requiring affected companies to develop and submit a 5-year pollution reduction strategy and file  a Release and Pollution Prevention Report (RPPR). The NJ Release and Pollution Prevention Report collects data for New Jersey Right to Know Act ( NJRTK).

What does the Federal PPA require?

Facilities must account for their use of toxic chemicals  and, where feasible, reduce their use.  Toxic pollution that cannot be reduced should be recycled, and pollution that cannot be recycled should be disposed of in an environmentally safe manner. 

EHS professionals must have a firm understanding of the processes that use toxic chemicals in order to reduce their use.  Documenting these activities is an important step in PPA compliance and must include an accounting for the final disposal of toxic chemicals.  Generally this is done using the EPA’s Toxic Release Inventory (TRI) Reporting Form R.  

For facilities in New Jersey, what else is required?

The New Jersey Pollution Prevention Act (NJ PPA), enacted in August of 1991, requires a Pollution Prevention (“P2”) Plan for facilities that meet specific requirements:

• A facility in New Jersey that files a Form R and a Release and Pollution Prevention Report (RPPR) under the New Jersey Worker and Community Right to Know Act for the same chemical(s) in two consecutive years.  Note that in New Jersey any employer required to submit a TRI Form R is also required to submit the RPPR.


• The chemicals listed in the Form R and RPPR remain at or above the TRI activity thresholds.

The facility must  prepare a five-year Pollution Prevention (P2) Plan and submit a P2 Plan Summary by July 1 once they become covered (the second year they submit an RPPR for the same chemical).  This becomes the “base year”.  For each of the following years that the facility remains at or above the TRI activity thresholds, the facility completes the P2-115 which compares pollution prevention progress for the reporting year to the base year.

The PPA Filing Process by an EHS Professional

When recently preparing PPA paperwork for a small biotech site, I had to collect a variety of information for preparing a New Jersey P2 Plan.  A brief review of the steps is listed below.  For detailed instructions, look at NJDEP Form DEP-113.

1. Contacted the company’s purchasing department to find out how much of each toxic chemical had been delivered to the facility. 


2. Contacted the company’s hazardous waste management contractor to confirm that the amount purchased (Step 1) equaled the amount that was disposed. 


3. Compare the purchased to disposed amounts. The amounts did not match. 


4. Investigate the discrepancy.  It turned out the waste management contractor was using a less accurate method for calculating the percentage of toxic chemical in our waste stream.  Their laboratory data indicated that the company was disposing of more toxic chemical than purchased.  Ultimately, the volume data from the company’s purchasing department was used since no new toxic chemicals could be produced by the company’s processes. 


5. Reviewed the company’s air permit for an estimation of the toxic chemicals lost to the air.


6. Calculated the chemical remaining as residue in the empty drums, which were also removed by our hazardous waste management contractor.


7. Contacted the site Controller for the facility SIC code.


8. Prepared a “Five-Year Use Reduction Goal” based on pollution prevention activities such as process improvements after a review of documentation of meetings where possible improvements were discussed with personnel who work with toxic chemicals as well as process engineering diagrams. (Sets site five year pollution prevention goals).
   
   
   
   • Progress towards these goals needs to be reviewed yearly and documented on the site P2 Plan.
   
   
   
   


9. Obtain signatures for plan from the “highest ranking corporate official with direct operating responsibility” and the “highest ranking corporate official at the facility”.

Note --- A P2 Plan Summary needs to be updated and submitted every five years for the chemicals referenced in the original P2 Plan submission.

This process needs to be repeated for each toxic chemical at each applicable facility in New Jersey with all of the information included as part of one P2 Plan regardless of the number of toxic chemicals reported.  The facility does need to file one RPPR for each chemical. Does this seem like a lot of work? Consider this:  In the twenty years since adoption, the PPA and NJ PPA have helped to substantially reduce the use and improper disposal of toxic chemicals by requiring industry to examine their work processes.

How about your facility?

As a facility, are you tracking your toxic chemicals and filing the appropriate PPA/NJ PPA documentation? Have you noticed that a mindful approach to the processes and paperwork have resulted in reduced usage and better, more healthful disposal of chemicals?

About Our Guest Blogger:  Charles Peruffo is an EHS professional specializing in laboratory health and safety. Prior to his EHS career, Charles spent many years as chemist in the pharmaceutical industry with responsibilities ranging from laboratory safety to analyst training.  He holds a Bachelor of Science in Biology from Montclair State University and is pursuing his Master of Science in Occupational Safety Health Engineering from New Jersey Institute of Technology.

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Topics: health and safety, General Industry H&S, General EHS, EPA, Emergency Response, Hazardous Waste Management, HazCom, Compliance, Air Sampling, reporting, chemical manufacturer, regulation, chemicals, Hazard Communication Standard, pollution prevention, pollution, chemical disposal, Right to Know

Topics: Emilcott, OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Emergency Response, H&S Training, Hazardous Waste Management, HazCom, worker safety, Occupational Health, Occupational Safety, MSDS, Hazard Communication Standard, Occupational Training, Safety Training in Spanish

John Quatermas - EHS Consultant

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Topics: OSHA, health and safety, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Hazard Communication Standard, environmental air monitoring, Occupational Training, Safety Training in Spanish